The Warren Court protected press freedom by constitutionalizing libel law. In its landmark decision New York Times Co. v. Sullivan (1964), the Court ruled that public officials could not recover damages for libel unless they showed by clear and convincing evidence that the press acted with actual malice—knowing falsity or reckless disregard as to the truth or falsity of statements. The case ensured that the press would not be liable for all factual errors, only those that were committed with actual malice.