rights circumstances for workers in the country. United Kingdom The United Kingdom abolished criminal libel on 12 January 2010 by section 73 of the Coroners and Justice Act 2009. There were only a few instances of the criminal libel law being applied. Notably, the Italian anarchist Errico Malatesta was convicted of criminal libel for denouncing the Italian state agent Ennio Belelli in 1912. Under English common law, proving the truth of the allegation was originally a valid defence only in civil libel cases. Criminal libel was construed as an offence against the public at large based on the tendency of the libel to provoke breach of peace, rather than being a crime based upon the actual defamation per se; its veracity was therefore considered irrelevant. Section 6 of the Libel Act 1843 allowed the proven truth of the allegation to be used as a valid defence in criminal libel cases, but only if the defendant also demonstrated that publication was for the "public benefit". United States Less than half of American states have criminal defamation laws, but the applicability of those laws is limited by the First Amendment to the U.S. Constitution, and the laws are rarely enforced. There are no criminal defamation or insult laws at the federal level. However, on the state level, 23 states and two territories have criminal defamation laws on the books: Alabama, Florida, Idaho, Illinois, Kansas, Kentucky, Louisiana, Massachusetts, Michigan, Minnesota, Mississippi, Montana, Nevada, New Hampshire, New Mexico, North Carolina, North Dakota, Oklahoma, South Carolina, Texas, Utah, Virginia, Wisconsin, Puerto Rico and Virgin Islands. In addition, Iowa criminalizes defamation through case law without statutorily defining it as a crime. Noonan v. Staples is sometimes cited as precedent that truth is not always a defence to libel in the U.S., but the case is actually not valid precedent on that issue because Staples did not argue First Amendment protection, which is one theory for truth as complete defence, for its statements. The court assumed in this case that the Massachusetts law was constitutional under the First Amendment without it being argued by the parties. Venezuela In March 2016, a civil action for defamation led to imposition of a four-year prison sentence on a newspaper publisher. Online defamation The rise of the internet as a medium for publication and the expression of ideas, including the emergence of social media platforms transcending national boundaries, has proven challenging