Gertz v. Robert Welch, Inc. (1974): Where P is not a
government official, as Sullivan was in Sullivan, then there is a
different standard for holding D liable, and this is what Gertz deals
with. P (Gertz, a prominent civil rights atty) sued D (the publisher
of the magazine of the John Birch Society) for statements claiming P
had various communist connections. When a private citizen, not a
government official, sues another private citizen for libel, is D’s
speech at all by the First Am.?
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