In the case of Caliga v. Inter Ocean Newspaper Company, artist A.B. Caliga sued the newspaper company for publishing a photograph of his painting without permission and alleged that it damaged his reputation as an artist by misrepresenting his work. The Supreme Court ruled in favor of the newspaper company, stating that once a piece of art is put on public display, its image becomes news matter and can be published freely by newspapers or other media outlets without infringing upon copyright laws. Furthermore, they found no evidence to support Caliga's claim about damage to his reputation since there was no malicious intent behind publishing the picture; rather it was done in good faith for informational purposes only.

In the dissenting opinion for Caliga v. Inter Ocean Newspaper Company, Justice Holmes disagreed with the majority's ruling that a newspaper company could not be held liable for defamation because it had merely published an artist's letter without malice. He argued that if a person repeats slanderous accusations knowing them to be false, they should bear responsibility regardless of whether or not they were the original author of those statements. Furthermore, he contended that even if there was no intent to harm on part of the newspaper company, its actions still resulted in damage to another individual’s reputation and therefore it should face consequences. The justice also pointed out potential implications this decision might have on future cases involving libel and slander laws.