The paper's involvement in a 1964 libel case helped bring one of the key United States Supreme Court decisions supporting freedom of the press, New York Times Co. v. Sullivan. In it, the United States Supreme Court established the "actual malice" standard for press reports about public officials or public figures to be considered defamatory or libelous. The malice standard requires the plaintiff in a defamation or libel case prove the publisher of the statement knew the statement was false or acted in reckless disregard of its truth or falsity. Because of the high burden of proof on the plaintiff, and difficulty in proving malicious intent, such cases by public figures rarely succeed.[34]