New York Times v. William James Sidis's Sullivan (1964) changed the nature of libel suits by establishing that public figures must demonstrate “actual malice” to recover a liability claim (Ibid 368 ) (Epstein and Walker 509). Curtis Publishing Co. v. Butts (1967) applied this standard to all public figures. In the case Gertz v. Robert Welch, Inc. (1974), Justice Powell argued that private individuals be afforded greater protection, pointing out that private citizens have less access to media channels and therefore less ability to refute defamatory articles published about them ( Duhart 374). However, public figures, he argues, are very similar to public officials in that they “must accept some necessary consequences of such involvement in public affairs” (Ibid). Furthermore, decisions citing Sidis, such as Friedan v. Friedan (1976), continue to ignore the passage of time as a means of weakening their status as a public figure (Ibid). Friedan had disappeared from the public eye for “only” sixteen years; Sidis had sought seclusion for nearly thirty years. “Thirty years of withdrawal from public life should put an end to the general public's interest in the actor14” but evidently this is not always the case (Digital Repository at Maurer Law 420). Unfortunately, it is still true that “the passage of time usually has little or no effect on the status of a public figure.” (Duhart