What was the significance of the Supreme Court ruling in Gertz v. Welch, Inc. (1974)? 

• That a private citizen does NOT have to meet the same burden of proof articulated in New York Times Co. v. Sullivan (1964) to win a defamation suit. 

• The Supreme Court reversed the federal and appellate court decisions. 

• The Court made a distinction between what private citizens and public figures had to establish to win a libel case.

• All of these