"In New York Times Co. v. Sullivan (1964), the Supreme Court reviewed an Alabama jury's award of damages to state officials who had been criticized in an editorial advertisement published in the New York Times. Realizing that politically motivated defamation actions could chill speech essential to informed self-government, the Court carved out a category of defamation for First Amendment protection.It thus adopted an "actual malice" standard that requires public officials to prove that an allegedly defamatory statement about them was made with knowledge of the falsehood or reckless disregard for the truth."