In the case of Hohensee v. News Syndicate, Inc., 1961, plaintiff John A. Hohensee sued News Syndicate for libel after they published an article about him in their newspaper that he claimed was false and defamatory. The Supreme Court ruled against Hohensee on the grounds that he had failed to prove actual malice on part of the defendant - a necessary requirement for public figures suing for defamation as established by New York Times Co. v Sullivan (1964). Furthermore, it was found that there were no factual errors in the article; rather, any negative implications drawn from it were due to its tone or interpretation which are not actionable under libel law.

The dissenting opinion in the case of Hohensee v. News Syndicate, Inc., argued that the court should have taken into account the fact that Mr. Hohensee was not a public figure and therefore did not need to prove actual malice on part of the defendant to win his defamation suit. The dissent also pointed out that there were factual disputes about whether or not certain statements made by News Syndicate were false, which should have been resolved by a jury rather than dismissed outright by summary judgment. Furthermore, it was argued that even if some statements could be considered opinions rather than facts, they still had potential to harm Mr. Hohensee's reputation and thus could potentially constitute defamation under Pennsylvania law.