Final answer:
Levesque had to prove actual malice in his defamation claim against Doocy due to U.S. Supreme Court precedent requiring public figures to show a statement was made with knowledge of its falsity or reckless disregard for the truth to protect freedom of speech.
Step-by-step explanation:
In the case of Levesque v. Doocy, Levesque had to prove actual malice to make out his defamation claim because of the legal standards set by the U.S. Supreme Court in landmark freedom of speech cases, which hold to a higher standard for public figures in defamation lawsuits. New York Times v. Sullivan established that public officials, to prove they were libeled, must show not only that a statement is false, but also that it was published with malicious intent or with reckless disregard for the truth. This requirement protects freedom of expression and makes it more challenging for public figures to win defamation cases, thereby helping to prevent abuse of defamation laws to silence critics.
The concept of actual malice is central to defamation cases involving public figures, where the claimant must demonstrate that the false statement was made with knowledge of its falseness or with reckless disregard for the truth. This protects the media's right to free speech under the First Amendment, especially in cases where they may publish negative but newsworthy information about public figures without fear of successful legal retribution, unless there is clear proof of actual malice.