What libel standard did Alabama use before New York Times Co. v. Sullivan?

Before the U.S. Supreme Court ruling in New York Times Co. v. Sullivan, Alabama applied a strict standard to libel cases. Under this state law, the expression of opinion was protected only if it rested on a completely accurate factual basis.1

In that legal environment, the burden of proof regarding accuracy fell entirely on the defendant (the speaker or publisher). If any published statements were found to be factually incorrect, the defendant lost their privilege of protection, regardless of whether the errors were minor or made in good faith. This approach contrasted with some other states, which allowed for minor factual errors if they were made inadvertently or with a good-faith belief in their correctness.1