Q: What were Dave’s comments on the Black-Goldberg-Douglas concurrence?
Dave’s comments
a. Sullivan does not apply to suits by private figure. Thus,
where P is not a government official, as Sullivan was, then there is
a different standard for holding D liable. See cases below.
b. How did the First Am. apply here, since the lawsuit was
between the private parties? Because Alabama’s state law of libel
affected the alleged free speech of Sullivan, and thus the First Am.
was involved via the Fourteenth Am.
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