ABSTRACT
The First Amendment issues regarding freedom of expression multiplied dramatically in the twentieth century; but serious unfinished business remains, and many new issues are forming in the regions of high technology. The always-uncertain line between public and private information—indeed the very nature of privacy itself in a modern society—could bring the subject of libel into the media arena more frequently as time goes by, and at greater cost until some basic changes are codified. New York Times v. Sullivan built a fence around public officials—a fence that would soon surround "public figures" such as movie stars and basketball players and columnists—and provided a "keep-out" sign for libel, though it left open that small gate called malice. The shadows cast by the Ariel Sharon and William Westmoreland libel trials fell upon the reputation of the media. Libel cases rarely provide cause for jubilation on either side.
