a difference in cases in which a private individual can prove he was libeled by a defendant who was at least negligent. He writes that as long as publishers are protected by having the burden of proof be on the plaintiff, there is little basis for a concern that a large amount of true speech is deterred unless a private person who is the victim of malicious libel can prove falsity. References External links Hepps, at BC CourtroomView.com ecasebriefs.com 1986 in United States case law United States Supreme Court cases United States Supreme Court cases of the Burger Court United States defamation case law United States First Amendment case law