"As the United States Supreme Court declared in the landmark case of Hustler v. Falwell, an advertising parody which portrayed the leader of the Moral Majority as having engaged in a drunken incestuous rendezvous with his mother, could not reasonably have been interpreted as stating actual facts about him."
January 1, 1970
https://en.wikiquote.org/wiki/Hustler_Magazine_v._Falwell