ABSTRACT

In March 1964, Justice William J. Brennan, Jr., possibly the Supreme Court's most ardent and effective advocate of free speech, wrote that in the United States, there is " [A] profound national commitment to the principle that debate on public issues should be uninhibited, robust, and wide-open," even i f those criticisms include "vehement, caustic, and sometimes unpleasantly sharp attacks on government and public officials" (New York Times 1964, 270). That recognition, Justice Brennan wrote, is at "[T]he central meaning of the First Amendment," and, therefore, citizens have more than a right to criticize their government and their governors, they have a duty to do so-as much a duty as it is the duty of government officials to administer (New York Times 1964, 273, 282).