In the 1958 case of Barr v. Matteo, the U.S. Supreme Court ruled in favor of Oscar R. Ewing and J. Howard McGrath who were sued for defamation by two former employees at the Federal Housing Administration (FHA). The plaintiffs, Matteo and Lyon, alleged that they had been defamed by a press release issued by Acting Director Robert L. Barr Jr., which implicated them in misconduct related to their roles at FHA. The court held that federal officials are entitled to absolute immunity from liability for defamation claims arising out of statements made within the scope of their official duties, even when such statements might be false or motivated by malice. This ruling was based on public policy considerations; it aimed to protect government officials from undue interference with their duties and encourage candid communication about matters of public concern without fear of potential litigation.

In the dissenting opinion for Barr v. Matteo, Justice Black disagreed with the majority's decision to extend absolute immunity to federal officials who make defamatory statements within their official duties. He argued that this broad interpretation of immunity could potentially shield malicious and corrupt behavior from legal consequences. Furthermore, he contended that such a wide-ranging protection was not supported by historical precedent or constitutional law. Instead, he believed in limiting immunity only to those actions which were necessary for an official to perform his duties effectively - a standard which would not cover defamation in most cases. In essence, Justice Black feared that granting absolute immunity might encourage abuse of power among government officials without providing adequate recourse for citizens who are wrongfully harmed by these abuses.