Which of the following does NOT accurately describe New York Times v. Sullivan (1964)?

A. The Supreme Court ruled that all libel plaintiffs must prove some level of fault.
B. The Supreme Court ruled that public officials must prove actual malice in libel suits.
C. The Supreme Court said we had a national commitment to the principle that debate on public issues should be robust, uninhibited, and wide open.
D. For the first time, the U.S. Supreme Court applied the First Amendment to libel law.
E. The Supreme Court said that, as a public official, Sullivan voluntarily took on a job that invited public attention and criticism.

Answer: A