Fault

NEW YORK TIMES V SULLIVAN (1964)

• A public official bringing a libel suit against a mass media defendant must prove actual malice.

GERTZ V WELCH (1974)

• In all libel suits against mass media defendants each state must require that the plaintiff show actual malice when the plaintiff is a public official or figure and at least negligence when the plaintiff is a private person.

• A private citizen plaintiff who has "thrust himself into the vortex" of an existing public controversy must prove actual malice in a libel suit against a mass media defendant. the plaintiff becomes a limited public figure.

• Under rare circumstances a private citizen may become an all-purpose public figure or an involuntary public figure.

• In order to win punitive damages, all plaintiffs must show actual malice.