structural:scholar_edition, linguistic:voice_change, information:filtering, linguistic:translation, quality:corruption
Further developments

Trump's opinion was supported by Supreme Court justice Clarence Thomas in various court opinions that followed. Thomas advocated reevaluating Sullivan in an opinion attached to the court's 2019 denial to hear a libel case brought by Katherine McKee, one of the women that accused Bill Cosby of sexual assault. McKee claimed Cosby had leaked a letter that permanently damaged her reputation. Lower courts rejected her case based on Sullivan, stating that she "thrust herself to the forefront of a public controversy", making her a limited public figure and requiring the higher standard of malice to be demonstrated. While Thomas wrote that the Court's decision to deny certification of McKee's appeal based on Sullivan was correct, he further said that Sullivan was made wrongly, and that "If the Constitution does not require public figures to satisfy an actual-malice standard in state-law defamation suits, then neither should we". Thomas also repeated calls to review Sullivan in his dissent in Berisha v. Lawson in 2021 and in his dissent to the court's denial to hear Don Blankenship 's appeal, in the latter saying that Sullivan allows news agencies to "cast false aspersions on public figures with near impunity". Justice Neil Gorsuch also joined in Thomas in Berisha in expressing his concerns of how the media landscape had changed since Sullivan.