Case citation: New York Times Co. v. Sullivan, 376 U.S. 254 (1964)

Background:

Montgomery, Ala. City Commissioner L. B. Sullivan sued the "New York Times" for libel after the paper ran an ad for a Civil Rights group about civil rights violations in Alabama. An Alabama jury awarded him $500 thousand in damages. After the Alabama Supreme Court upheld the award, the Times appealed the case to the Supreme Court. 

Decision: Reversed 

Test - Actual Malice: 

Public officials can only collect damages for defamation if they can prove that the defamatory statements were published with reckless disregard of the truth.

Private citizens only have to prove negligence.