In 1964, the Supreme Court decided the landmark case of New York Times Co. v. Sullivan. The New York Times had published an ad during the civil rights movement requesting donations to support Martin Luther King Jr. on his defense against perjury charges. Unfortunately, the ad contained some misleading and inaccurate information and offended the city public safety commissioner, who sued for libel. The Supreme Court ruled in favor of the publication, establishing the “actual malice” standard for libel cases concerning public figures—meaning a statement has to be made “with knowledge that it was false or with reckless disregard of whether it was false or not.”