In the United States v. Press Publishing Company case of 1910, the Supreme Court ruled that a newspaper could be held liable for libel against a foreign leader, even if the statements were not made with malicious intent. The Press Publishing Company, which published New York World newspaper was sued by the U.S government after it printed articles alleging corruption by President Diaz of Mexico and his administration. The court found that such publications could potentially damage diplomatic relations between countries and thus constituted an offense under federal law. It upheld this principle despite acknowledging that there may have been no actual malice in publishing these allegations or intention to defame President Diaz personally. This decision underscored how considerations of international diplomacy can override freedom of press protections in certain circumstances.

In the dissenting opinion for United States v. Press Publishing Company, Justice Oliver Wendell Holmes Jr. argued that the newspaper article in question did not obstruct justice as it was published after the trial had concluded and therefore could not have influenced its outcome. He contended that a publication can only be considered contempt of court if it poses a clear and present danger to the administration of justice, which he believed was not applicable in this case since there were no ongoing proceedings at risk of being disrupted by public sentiment stirred up by media coverage. Furthermore, he expressed concern about limiting freedom of speech and press based on speculative harm to judicial integrity or reputation rather than concrete evidence of interference with due process or fair trials.