of whether it was false or not". In sum, the court held that "the First Amendment protects the publication of all statements, even false ones, about the conduct of public officials except when statements are made with actual malice (with knowledge that they are false or in reckless disregard of their truth or falsity)." While actual malice standard applies to public officials and public figures, in Philadelphia Newspapers v. Hepps (1988), the Court found that, with regard to private individuals, the First Amendment does "not necessarily force any change in at least some features of the common-law landscape". In Dun & Bradstreet, Inc. v. Greenmoss Builders, Inc. (1985) the Court ruled that "actual malice" need not be shown in cases involving private individuals, holding that "[i]n light of the reduced constitutional value of speech involving no matters of public concern... the state interest adequately supports awards of presumed and punitive damages—even absent a showing of 'actual malice'." In Gertz v. Robert Welch, Inc. (1974), the Court ruled that a private individual had to prove malice only to be awarded punitive damages, not actual damages. In Hustler Magazine v. Falwell (1988), the Court extended the "actual malice" standard to intentional infliction of emotional distress in a ruling which protected parody, in this case a fake advertisement in Hustler suggesting that evangelist Jerry Falwell's first sexual experience had been with his mother in an outhouse. Since Falwell was a public figure, the Court ruled that "importance of the free flow of ideas and opinions on matters of public interest and concern" was the paramount concern, and reversed the judgement Falwell had won against Hustler for emotional distress. In Milkovich v. Lorain Journal Co. (1990), the Court ruled that the First Amendment offers no wholesale exception to defamation law for statements labeled "opinion", but instead that a statement must be provably false (falsifiable) before it can be the subject of a libel suit. Nonetheless, it has been argued that Milkovich and other cases effectively provide for an opinion privilege. Private action Despite the common misconception that the First Amendment prohibits anyone from limiting free speech, the text of the amendment prohibits only the federal government, the states and local governments from doing so. State constitutions provide free speech protections similar to those of the U.S. Constitution. In a few states, such as California, a state constitution has been interpreted as providing more comprehensive