Laws ch. 753, at 1234. The legislature has not made any significant revisions to section 609.765 since its 1963 codification. After the codification of its present form, the United States Supreme Court handed down multiple, seminal libel and defamation cases that control our analysis. In New York Times Co. v. Sullivan, the Supreme Court held that the Constitution limits state power, in a civil action brought by a public official for criticism of his official conduct, to award damages for a false statement only if the public official can prove that “the statement was made with ‘actual malice’—that is, with knowledge that it was false or with reckless disregard of whether it was false or not.” 376 U.S. 254, 279-80, 84 S. Ct. 710, 726 (1964). In Garrison v. Louisiana, the Supreme Court extended its holding in New York Times to criminal defamation of a public figure. 379 U.S. 64, 85 S. Ct. 209 (1964). The Garrison Court held that a Louisiana criminal libel statute incorporated constitutionally invalid standards in the context of criticism of public officials, because it directed punishment for true statements made with malice. Id. at 78, 85 S. Ct., at 217. The Supreme Court, consistent with its decision in New York Times, ruled that such statements were constitutionally privileged unless made with actual malice, defined as knowledge that the statements were false or made with reckless disregard for their truth or falsity. Id. at 74-75, 85 S. Ct. at 215-16. Garrison established truth as an absolute defense “where the criticism is of public officials and their conduct of public business.” Id. at 72-73, 85 S. Ct. at 215. 6