New York Times vs. Sullivan (1964) is considered a defamation case, although other issues of the law were also taken into consideration during the decision making. Defamation is defined as false communication that is harmful to reputation. The reason why this was a unique case was that for the first time the respondent, in this instance the high-ranked police commissioner, sued the newspaper for defamatory remarks against him but had to prove that the depiction of him in the newspaper was false. The Court referred back to older cases that had similar situations with public government officials. Some of these cases include Coleman vs. MacLennan (1908), Snively vs. Record, and Lafferty vs. Houlihan. In all three instances, the court ruled in favor of the newspapers on accounts that there was no malice. Actual malice is proving that a defamatory statement was made with the knowledge that it was false. The verdict of the Sullivan case was unanimous: 9 votes for New York Times and 0 for Sullivan.