Scholars have long recognized the marketplace of ideas rationale for the immunity that citizens of the United States enjoy from liability for expressive speech. This theory was addressed by Justice Holmes in his dissent in Abrams v. United States in which he stated: “when men have realized that time has upset many fighting faiths, they may come to believe . . . that the ultimate good desired is better reached by free trade in ideas . . .”. The introduction of the doctrine of seditious libel, however, undercut this foundational First Amendment theory and buttressed a controversial First Amendment limitation: that is, the extent to which opinion speech, political or otherwise, can be suppressed when it fallaciously brings a public official into disrepute. When an opinion contributes little value to advancing public debate or transaction of ideas, the expression itself arguably becomes subordinate to the substantial interest a public official has in being insulated from reputational harm.