"It would be misleading to say that Hustler v. Falwell extended the scope of First Amendment speech protections. What the Supreme Court did, essentially, was to preserve the scope that already existed, which they did by rejecting an effort by the Appeals Court to allow a public figure, absent a finding of libel, to recover on a claim of emotional distress."
January 1, 1970
https://en.wikiquote.org/wiki/Hustler_Magazine_v._Falwell