At the height of the modern civil rights movement, The New York Times ran a full-page advertisement entitled “Heed Their Rising Voices.” The advertisement detailed police efforts in Montgomery, Ala., to suppress the nonviolent civil rights demonstrations being carried on there by thousands of college students. The police commissioner of Montgomery, L.B. Sullivan, filed a lawsuit against The New York Times, alleging that he had been libeled by information carried in the advertisement, even though he was never mentioned by name. Should the Court use the actual malice test in this case to determine whether the newspaper libeled the commissioner? Explain. New York Times Co. v. Sullivan, 376 U.S. 254 (U.S. Sup. Ct.).