exclusively to state law through 1964 "the new york times" versus sullivan the supreme court brought in the first amendment with cases involving public officials in those cases actual malice standard applied but in the remainder is still governed by state law which generally allows you if the reporting was false and negligent under "the new york times" standard you have to prove you actually knew it was false and subjective and that you acted with reckless disregard. that was expanded by some bright media lawyers into people public figures a few years later but then they applied it with rosenblum to metro media supreme court shortly after that realize