In Rosenbloom v. Metromedia, Inc., the U.S. Supreme Court considered whether a radio station could be held liable for defamation of a private individual involved in matters of public concern without proof that the statements were made with actual malice (knowledge they were false or reckless disregard for their truth). The case arose when George Rosenbloom sued Metromedia, Inc., after its Philadelphia-based radio station broadcasted reports falsely implying he was involved in distributing obscene material. The court ruled 5-4 in favor of Metromedia, extending the "actual malice" standard from New York Times Co. v. Sullivan to cases involving private individuals if they are engaged in issues of public interest or concern; thus protecting news media from liability unless it can be proven that they knew their information was false or acted recklessly regarding its veracity.

In the dissenting opinion for Rosenbloom v. Metromedia, Inc., Justice Harlan argued that the majority's decision to extend First Amendment protections to defamatory statements about private individuals involved in matters of public concern was misguided. He contended that this approach neglected important differences between public figures and private individuals, particularly their ability to respond effectively to false accusations and their voluntary exposure to increased risk of injury from defamation. Instead, he proposed a more nuanced standard: when speech concerns a matter of legitimate public interest, truth or falsity should be determined by whether the defendant acted with "reasonable grounds for believing" its veracity at the time it was published. This would balance free press rights against an individual’s right not be subjected unfairly to damaging falsehoods.