References:

EXTENSION OF SULLIVAN'S ACTUAL MALICE ... - HeinOnlineheinonline.org › hol-cgi-bin › get_pdf › geolr2
standard of actual malice should include persons who are not public officials, but are public figures involved in issues of justified and important public interest.' 2.

Defamation: Extension of the Actual Malice Standard to ...scholarship.kentlaw.iit.edu › cgi › viewcontent
by JR Bayer · ‎1983 · ‎Related articles
complaint stated a cause of action, but disagreed with the majority's opinion that the New York Times standard of actual malice should apply. This highly critical ...

Constitutional Law -- Defamation under the First ... - COREcore.ac.uk › download › pdf
by JR Carpenter Jr · ‎Cited by 4 · ‎Related articles
standard of actual malice in Butts than that applied to public officials. By applying a different standard the Court may be doing what Mr. Justice Black describes ...

The U.S. Supreme Court should revisit its foundational rulings ...news.bloomberglaw.com › us-law-week › cosby-defam...
Feb 19, 2019 — The U.S. Supreme Court should revisit its foundational rulings on libel grounded in the standard of actual malice after turning away a request to ...

There is no indication from the question, apart from being litigation possibly in a civil case, that this is one of defamation - libel or slander - POR PARTE DE MI REPRESENTADA: on my clients' part.