The U.S. Supreme Court case of New York Times Co. v. Sullivan revolutionized the law of libel, introducing a requirement for proof of “reckless disregard” for the truth of the statement in question. The case is considered key in the support of freedom of the press. In March of 1960, the New York Times featured an advertisement asking for donations to support the defense of Martin Luther King Jr. with respect to his civil rights activities in Alabama. The actions of the Alabama police were described inaccurately and in unflattering terms, leading the Montgomery public safety commissioner, L. B. Sullivan, to ask the Times for a retraction. The Times, believing that Sullivan did not represent the state and its employees, did not comply, and Sullivan later won a libel suit against the paper. The Times asked the Supreme Court to reconsider the decision. A unanimous Court sided with the Times, saying that Sullivan had not been named in the advertisement and thus had not been libeled. Moreover, factual error could not provide a cause of action for libel; proof of “actual malice” behind the error was required.