How did Hugo Black, William O. Douglas, and Arthur Goldberg view First Amendment protection for criticism of officials?

In the landmark case New York Times Co. v. Sullivan (1964), while all nine Supreme Court justices agreed that the First Amendment required a higher standard for libel suits brought by public officials, Justices Hugo Black, William O. Douglas, and Arthur Goldberg held a more expansive view than the majority opinion.1

These three justices believed that the First Amendment provided an absolute privilege for critics of official conduct. Consequently, they argued that such criticism should be protected even if the statements made against public officials were maliciously false. This position went further than the court's ruling, which established that public officials must prove "actual malice"—knowledge of falsity or reckless disregard for the truth—to succeed in a libel claim.1