In the case of Monitor Patriot Co. et al. v. Roy, 1970, the U.S Supreme Court ruled in favor of a newspaper company that had been sued for libel by a political candidate who claimed an editorial cartoon published about him was defamatory and damaging to his reputation. The court held that public figures like politicians must prove actual malice on part of the publisher (i.e., knowledge that statements were false or made with reckless disregard for truth) to win defamation suits under First Amendment protections extended to publishers in previous rulings such as New York Times Co v Sullivan (1964). In this case, it was determined there wasn't sufficient evidence proving actual malice from Monitor Patriot Company towards Laurence E. Roy.

In the dissenting opinion for Monitor Patriot Co. et al. v. Roy, Justice Hugo Black argued that the First Amendment should protect newspapers from libel suits brought by private individuals unless there is proof of actual malice - knowledge that a statement was false or made with reckless disregard for its truthfulness. He believed this standard, established in New York Times Co. v Sullivan (1964), should apply to all defamation cases involving matters of public concern regardless of whether the plaintiff is a public official or private individual because it would promote robust debate on important issues without fear of crippling financial liability and self-censorship due to potential lawsuits.