Laws are always changing and developing, however there are a handful of court cases throughout history that have proven to be particularly significant in this process. Times v. Sullivan was pivotal in determining how the court looked at defamation cases. This court case created the test of actual malice, which provides a stricter standard for defamation. This stricter standard helps to maintain First Amendment protection for all speech. The Times v. Sullivan decision had a tremendous impact on the libel and defamation cases that followed. Two examples of this are found in Times Inc. v. Pape, a libel case that began before Times v. Sullivan was decided and finished after the final verdict was reached, and Walter v. Courier-Journal, Louisville Times Company and WHAS, Inc. This case clearly demonstrated the influence that Times v. Sullivan would have on future defamation cases.