In the 1969 case Greenbelt Cooperative Publishing Association, Inc. v. Bresler, the U.S Supreme Court ruled in favor of a newspaper publisher who was sued for libel by a real estate developer named Charles Bresler. The controversy arose when the newspaper reported that local citizens at public meetings had characterized Bresler's negotiation tactics with city officials as "blackmail." Despite these statements being metaphorical and not accusing him of committing actual crime, Bresler claimed this damaged his reputation. However, the court unanimously held that even though words like "blackmail" have criminal connotations when used literally, their use in this context could not be construed as stating or implying defamatory facts about an individual because it was clear they were used in a figurative sense during heated political debate where hyperbolic language is common. Therefore, there was no liability on part of the publishing association under libel laws.

In the dissenting opinion for Greenbelt Cooperative Publishing Assn., Inc. v. Bresler, Justice Black argued that the First Amendment should not protect false statements about public figures or officials made with actual malice - knowledge of their falsity or reckless disregard for their truth. He believed that such protection would undermine public trust and respect in government institutions by allowing malicious lies to circulate without consequence. Furthermore, he contended that this ruling could potentially discourage individuals from serving as public officials due to fear of being subjected to unfounded accusations and defamation without any legal recourse available against those who spread these falsehoods intentionally or recklessly.