Let's go with answer D -- that it's difficult for public officials to win libel suits.
The matter at issue in New York Times vs. Sullivan was an ad that ran in the New York Times which described police actions against Martin Luther King, Jr. and other civil rights protesters. There were some inaccuracies in the ad, and Montgomery, Alabama commissioner of Public Safety, L.B. Sullivan, argued that the ad defamed him and the police.
Ultimately the case became a landmark Supreme Court decision, which set the standard of "actual malice" for libel. Actual malice on the part of those who placed the advertisement would have to be proved in order for such a case to be declared libelous. The inaccuracies in the advertisement were errors, not intentional acts of malice. Public figures must prove reckless disregard of the truth in order to win a libel case, and they rarely are able to do so.
