How did the views of Black, Douglas, and Goldberg differ from Justice Brennan’s actual-malice standard?

In New York Times Co. v. Sullivan (1964), while all nine justices reached a unanimous decision, Justices Hugo Black, William O. Douglas, and Arthur Goldberg held a more expansive view of the First Amendment than the "actual-malice" standard established by Justice William Brennan.1

While Brennan’s opinion required public officials to prove that a statement was made with "actual malice"—defined as knowledge of falsity or reckless disregard for the truth—to succeed in a libel suit, the three concurring justices believed the Constitution provided even greater protection. Black, Douglas, and Goldberg argued that the First Amendment created an absolute privilege for critics of official conduct. Under their interpretation, this protection would extend to such criticism even if the statements were proven to be maliciously false.1

Essentially, while Brennan sought to constitutionalize defamation law to ensure "uninhibited, robust, and wide-open" debate, these three justices advocated for a standard that would remove the threat of libel litigation for critics of government officials entirely.1