In the case of Henry v. Collins (1964), the U.S. Supreme Court ruled in favor of a Mississippi man, Aaron Henry, who had been sued for libel by a local police chief, James L. Collins Jr., over comments made during an NAACP meeting that were later broadcast on television and radio. The court found that there was insufficient evidence to support the claim that Henry's statements were false or damaging to Collins' reputation as required under Mississippi law for a successful defamation suit. Henry had accused Collins and other officials of beating two African American prisoners without cause; allegations which they denied and led them to sue him for libel seeking $50,000 in damages each. However, Justice Hugo Black writing for the majority stated: "We hold only that where a newspaper publishes false defamatory facts about an individual...the Constitution does not prohibit recovery." This ruling reaffirmed First Amendment protections against defamation suits brought by public officials unless it can be proven there was actual malice involved - knowledge that information is false or reckless disregard whether it is true or not.

In the dissenting opinion for Henry v. Collins, Justice Hugo Black argued that the majority's decision to reverse and remand was unnecessary. He believed that there was no need for further proceedings because it had already been established in a previous trial court hearing that the petitioner’s arrest violated his constitutional rights under both state and federal law. According to him, this violation should have led directly to an overturn of his conviction without any additional hearings or trials required. Furthermore, he criticized the majority's reliance on a technicality regarding whether or not certain evidence could be considered by appellate courts when determining if constitutional violations occurred during lower court proceedings. In essence, Justice Black felt strongly that procedural complexities should not stand in the way of protecting individuals' fundamental rights.