Curtis Publishing Co. v. Butts
The U.S. Supreme Court extended the constitutional privilege announced in New York Times v. Sullivan to protect defamatory criticism of nonpublic persons "who are nevertheless intimately involved in the resolution of important public questions or, by reason of their fame, shape events in areas of concern to society at large." Butts, 388 U.S. at 164 (Warren, C. J., concurring in result)). As Chief Justice Earl Warren noted in concurrence, "our citizenry has a legitimate and substantial interest in the conduct of such persons, and freedom of the press to engage in uninhibited debate about their involvement in public issues and events is as crucial as it is in the case of 'public officials.'" Butts, 388 U.S. at 164.
Later, in Gertz v. Robert Welch, Inc., 418 U.S. 323, 342 (1974), the U.S. Supreme Court also determined that both for public officials and public figures, a showing of New York Times malice is subject to a clear and convincing standard of proof.