A jury in New Hampshire Superior Court awarded P damages in this civil libel action based on one of D's columns in the Laconia Evening Citizen. P alleged that the column contained defamatory falsehoods concerning his performance as Supervisor of the Belknap County Recreation Area, a facility owned and operated by Belknap County. D appealed. Between the trial and the decision of D's appeal by the New Hampshire Supreme Court, the Supreme Court decided New York Times Co. v. Sullivan. The Supreme Court held that a State cannot award damages to a public official for defamatory falsehood relating to his official conduct unless the official proves actual malice -- that the falsehood was published with knowledge of its falsity or with reckless disregard of whether it was true or false. The New Hampshire Supreme Court affirmed. D appealed.

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