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In New York Times v. Sullivan, the Supreme Court extended First Amendment protection to a class of defamation--that which is directed at officials of the government. To guarantee that defamatory speech received a full measure of constitutional protection, Justice Brennan set out specific procedural safeguards to protect defendants in defamation actions. This paper argues that these safeguards, often ignored in legal scholarships, are fully as important as the substantive test set out in Brennans opinion.