Subsequent Developments
Guilford later joined the staff of the Twin City Reporter. He continued to draw the ire of organized crime in Minneapolis and was shot and killed on September 6, 1934.
The Court closed off one of the few outlets remaining to censor the press under Near in New York Times Co. v. Sullivan, which seriously limited the grounds upon which a public official could sue for libel. Statements made regarding their official conduct were only actionable if made with "actual malice," meaning a knowing or reckless disregard for the truth.
Hustler Magazine v. Falwell excluded parodies from even this limited standard, as they included no actionable statements of fact. Hustler made clear this protection extended beyond merely defamation suits to cover other torts such as intentional infliction of emotional distress.
Read more about this topic: Near V. Minnesota
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