According to case law, what must public figures demonstrate in addition to actual malice?

Public figures must demonstrate "deliberate indifference to the truth" in addition to actual malice to succeed in a defamation claim. This legal standard stems from the landmark Supreme Court case New York Times Co. v. Sullivan, where the Court established that actual malice involves knowledge of falsity or reckless disregard for the truth. Deliberate indifference to the truth refers to a conscious or reckless disregard for the information being reported. This means that the public figure needs to show that the defamatory statement was made despite a significant awareness of its potential falsehood, reflecting a serious level of disregard for the truth.

This standard is considered necessary to protect freedom of speech and the press, especially in political discourse, thereby requiring public figures to meet a higher evidentiary burden than private individuals. Overall, the focus on both actual malice and deliberate indifference ensures a balance between protecting reputations and allowing for robust public debate and discussion.