FYI...
"That all changed in 1964 when the Supreme Court issued a ruling that revolutionized libel law in the United States. The famous decision in New York Times Co. v. Sullivan once and for all created a national rule that squared more fully with the free press guarantees of the First Amendment. In its ruling, the Court decided that public officials no longer could sue successfully for libel unless reporters or editors were guilty of "actual malice" when publishing false statements about them.
And just what is malice when it comes to proving libel? Retired Justice William J. Brennan, Jr. (a Delt, BTW), who wrote the Sullivan decision, defined it as "knowledge that the [published information] was false" or that it was published "with reckless disregard of whether it was false or not." In other words, public officials no longer could sue for libel simply by proving that something that had been broadcast or printed about them was false. Now they would have to prove that a journalist had knowingly printed false information while making little, if any, attempt to distinguish truth from lies."
The rest of the article can be found here:
http://usinfo.state.gov/products/pubs/press/press08.htm
Another thing that I think I remember from my days in the newsrooms is that only a person can be libeled, not an institution such as a university. I may be wrong about that.