No Liberty to Libel: Rethinking Free Speech In America

In this episode of Roots, Rights & Reason, Lee Smith welcomes Carson Holloway, Washington Fellow in the Claremont Institute’s Center for the American Way of Life and author of No Liberty to Libel: The Constitutional Case Against New York Times v. Sullivan. Holloway examines one of the most consequential Supreme Court decisions in modern history, arguing that the “actual malice” standard established in New York Times v. Sullivan has strayed from the Constitution’s original meaning and made it extraordinarily difficult for public figures to defend their reputations against false and damaging claims.

Drawing on the Founders’ understanding of natural rights, Holloway explains that reputation was once regarded as a fundamental right alongside life, liberty, and property. As today’s media landscape is shaped by rapid information cycles, anonymous sourcing, and the widespread reach of digital platforms, the conversation raises urgent questions about accountability, public trust, and the future of American discourse, and whether the Supreme Court may be ready to revisit one of its most influential First Amendment precedents.

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Transcript

SPEAKER_02 0:02

From the brave roots of our father. To the unstoppable force of American ingenuity. To the sacred inheritance of freedom we must protect. This is our legacy. Join investigative journalist Lee Smith on Roots, Rights, and Reason. Powered by America's future.

SPEAKER_01 0:21

Hi, I'm Lee Smith. Welcome and thanks for joining us for this new episode of Roots, Rights, and Reason. This week we're discussing free speech in the digital age and whether there are limits to free speech. Like libel. Libel is defamation expressed in written form, such as newspapers, online articles, or broadcasts that harms a person's reputation. U.S. libel law aims to balance two important values, protecting individuals from false, damaging statements, and preserving freedom of speech. The most decisive case shaping modern libel law is New York Times Company versus Sullivan. In March 1960, the New York Times published an advertisement criticizing police actions during the civil rights movement in Montgomery, Alabama. And in response, L. B. Sullivan, a city commissioner, sued for libel. He claimed that, although he was not named directly, the statements implied criticism of his conduct. The Supreme Court ruled unanimously in favor of the Times and established the actual malice standard. This required public officials to prove that a defamatory statement was made knowingly false or with reckless disregard for the truth. This decision gave the press broad protection when discussing public issues, ensuring that fear of lawsuits would not silence criticism of government officials. Others believed that the decision made the press reckless and put it on course for politicization. Our guest today argues that the decision lacks grounding in the Constitution's original meaning. Instead, the court effectively created the actual malice rule as a matter of policy rather than deriving it from historical libel law. By making it extremely difficult for public officials to win libel cases, the Sullivan standard may allow false statements to circulate widely without sufficient legal consequences. These concerns are echoed by members of the current Supreme Court, including Justice Clarence Thomas and Justice Neil Gorsuch. Justice Thomas has argued that Sullivan departed from the Constitution's original understanding and should be reconsidered. Justice Gorsuch, while not fully rejecting the case, has questioned whether its broad protections still make sense in today's media environment, where misinformation can spread rapidly online and cause significant harm. Today we're speaking with Carson Holloway, department chair and professor of political science at the University of Nebraska, Omaha, and a Washington fellow in the Claremont Institute Center for the American Way of Life. Also author of the just published book No Liberty to Libel, the Constitutional Case Against New York Times versus Sullivan. Carson, thanks so much for being here with us today. And let's get right to the heart of it.

SPEAKER_00 3:22

What exactly is libel? Libel is a traditional aspect of American and English law and also many other jurisdictions, too, but I'm familiar with the American version. It's an aspect of law by which someone can sue to recover their reputation if they've been defamed. Broadly speaking, defamation is a tax on another person's reputation, an unjust attack or an unwarranted attack, a false attack often. And then the two subcategories of defamation are slander, which is spoken, and libel, which is published. So really libel is a published defamatory matter for which someone can seek redress in the courts if the material is false and injurious to the reputation.

SPEAKER_01 4:06

Our standard here in the United States, and this is what your great new book is about, the standard that we have right now in the United States, it's based on a um, I believe the ruling is 1964, but it goes back to a 1960 um uh event when the New York Times published, I believe it was an advertisement, uh, and and the and um there there uh a lawsuit was brought. Um if you can explain that and how New York Times versus Sullivan, or is it Sullivan versus New York Times, how that became the benchmark for deciding uh libel cases. It's it seems to me uh uh especially important. I I should have said this before, but it it's it's not just challenging this, but uh but in the circumstances that we have now, the media itself is very different as well. Social media, all sorts of stuff we see flying around. So it strikes me that that this but that this uh benchmark decision is really important for us to understand.

SPEAKER_00 5:04

Yeah, thanks, Lee. That's a good way to get into these issues. Um I can say a little bit about the origins of the case, and then something more important, I think, about the the consequences of the case. It is a case that emerged out of the civil rights movement, um, an ad advertisement, a political advertisement that was put in the New York Times in 1960, uh carrying a message in defense of Martin Luther King and his activities on behalf of the civil rights movement, and a criticism of Southern officials' intransigence and abusive behavior in the face of that movement. The ad did contain some inaccuracies for which L. B. Sullivan, who was uh Montgomery County Commissioner, or city commissioner rather, sued for libel and won in the courts of Alabama. Um, it was appealed by the New York Times up to the Supreme Court of the United States, and the Supreme Court sided with the Times. Uh, and there are various reasons to think that it was probably better that Sullivan should lose, um, which I won't go into now. But the important thing about the case for my purposes is that the court used it as an occasion to really reconfigure America's libel standards, America's First Amendment standards. So traditionally, in American libel law, if you were the victim of false defamatory publication, you would be able to sue and recover damages for that. And the fact that the publication was false and defamatory would generally speaking be enough for you to prevail, right? The Times Court, or the Times versus Sullivan Court, in an opinion written by Justice William Brennan, one of the most consequential liberal jurists of his time and very important justice, uh, they came up with a new standard for a particular category of people. So this is the innovation that they applied to public officials. L. B. Sullivan, as I said, was a city commissioner, so he's a public official. And then later they expanded it to apply not only to public officials, but broadly speaking, public figures. So the new standard was that if you're going to sue successfully, and you fall into those categories, you're going to sue successfully reliable, you're a public official or a public figure, you will have to demonstrate actual malice. Actual malice is a term of art uh adopted by the Supreme Court in that case to mean that the publisher either knew that the thing was false and published it anyway, or at least acted with reckless disregard for the truth or falsity. So it's really sets up a kind of two-tiered system where ordinary people don't have to meet that standard, but public officials and public figures do. And my argument is an originalist argument. I'm contending that this is not really required by the original meaning and the historical meaning of the First Amendment. And that's why I would like the Supreme Court to revisit it. Thinking about the consequences, it does set up a very, very high standard that makes it close to impossible for a public figure or a public official, public official to defend their reputation through a libel suit. It's very difficult to prove actual malice. Who is a public figure?

SPEAKER_01 8:10

I mean, we we know that George Clooney is a public f figure. George W. Bush, the 43rd uh president of the United States, is a public figure. You've written a book, which is available to the public. You're going to be doing interviews. You're doing this great interview with us here on Roots, Rights, and Reason. Do are you a public figure? How do they decide who's a public figure? Am I a public figure? Because I interview people and we have this show regularly on on which which appears on social media and in all other places.

SPEAKER_00 8:41

I think that you probably are almost certainly a public figure, and I might well be one. That's a big problem, I think, an additional problem with the doctrine. This this um category of public figure is not very easily defined. And the courts in the post-New York Times versus Sullivan era, it took you know a lot of cases after the Times case to kind of hash out the doctrine and see how far it applies. But the courts have even gone so far as to say that there's like two versions of public figures. There's the generalized public figure. We could say that, for example, somebody like Elon Musk is a public figure, no question. Or say Donald J. Trump, when he was not yet president, was clearly a public figure because he was running for office. But then they've got this other category of limited purpose public figure, right? So somebody who's become a public figure for the purpose of a certain controversy or issue. So it is easy for even ordinary people to get swept up into this uh if they've involved themselves in some controversy, or even if the controversy kind of came and grabbed onto them. And that's something that I think uh some people might be ready to rethink. Maybe the public figure category is too expansive. And I would welcome that kind of rethinking, although again, my argument is kind of going more to the roots of the question and contending that the court really, in the Times opinion, departed significantly from the older traditional and founding era view of how libel and and freedom of speech should be thought about.

SPEAKER_01 10:09

Well, the I mean, I this is really important. So I mean I let let's go into that some and then come up to the future um and say, because it seems that what you're talking about, the what's really um derived from the Constitution may be the kind of thing that especially now we need. We need in a different uh we needed a different era. I mean, the media since 1960, since 1964, this is 60 years, has changed, changed pretty profoundly. So yeah, so let's dig in a little bit. What got you interested in this case? I mean, you're you're you're you're not a constitutional lawyer. Um, so what what was it about what was it about uh New York Times or Sullivan?

SPEAKER_00 10:50

That's right. I'm not a lawyer, I'm a professor. I do teach constitutional law in undergraduate classes, and I've done that for a long time. Um, and I, you know, I've long been persuaded that originalism is the proper approach to constitutional interpretation. Uh, I don't think judges should be turning the constitution into a living constitution, which I find means making it mean what they think it should mean today. And so, in the course of my teaching and then research and publication on these questions, I've done other work in American constitutionalism. I became aware of it, and not I'm not the only one to be aware of this. I've learned it from other people, but uh yeah, the courts drift away from original meaning and from a kind of more modest conception of its own authority. And once you get studying that, you become aware of more and more cases that look questionable, especially ones from the 1960s. And as someone who follows the court pretty carefully, I've seen it undoing certain errors of the past based upon a renewed respect for the original meaning of the constitution. So I wanted to, I mean, I I was interested in this case because I've taught it many times. I the more I read it, the more I thought about it, the more it seemed like a constitutional error to me. And so I wanted to make that argument at length.

SPEAKER_01 12:07

Are your students surprised to know that that's that that right now, that that is kind of what decides that's what decides libel cases? I mean, that's standard.

SPEAKER_00 12:17

Yeah, I think so, somewhat. Although, you know, there are a lot of students and a lot of people in America are accustomed to just taking without question whatever the Supreme Court says about the meaning of the Constitution and and assuming that the court's infallible. That, of course, is not the case. There's a lot of things that ought to be rethought. And of I should also add, though, there have been famous people in American politics in the last few years who have started raising questions about these standards. President Trump has done it, Governor DeSantis in Florida. And we mentioned earlier the uh the opinions by Gorsuch and Justice Thomas. So it seemed like there was getting to be a kind of public interest in this question that I wanted to try to address as well.

SPEAKER_01 12:59

I mean, it seems like it's uh the the um the interest and and your book, I mean, uh just to come back to this briefly, it seems very timely because when we're talking, uh when we're talking about what's happening online and the internet, and people are concerned about the uh various censorship regimes that we've endured, and people talk about, oh, we don't want to return to this, freedom of speech. And I think in some ways, free free speech is being um, or the the concept is being abused, subject to some abuse, uh, because I as as as far as I can tell, the uh information operations waged by hostile powers on social media, they that there is no right. Uh the Chinese intelligence have do not have a constitutional right to wage information warfare against Americans. Do you think that a proper understanding, a constitutional understanding of libel will help eliminate some of this debate that we have about uh about stuff online, about censorship, about what's what's free speech? Because a lot of this is a lot of this is uh is is libeless, a lot of the stuff that they're saying.

SPEAKER_00 14:06

Yeah, this is a really great point. And going back to the founders again for just a moment, if you read, for example, the Federalist Papers, other debates over the ratification of the Constitution, you see over and over again that the founders were painfully aware that a republic, an open society such as ours, is subject to foreign influence. They did not like that. I mean, to be a really self-governing people, you have to be free to deliberate yourselves based upon your own interests and your own considerations without foreign nations trying to discombobulate your reasoning with a bunch of false or self-interested information. So there's more at stake than just reputation. There's the people's ability to deliberate freely and rationally about the direction of the country. And certainly we don't want censorship. Um, but I would say that libel is really a different category than censorship. It doesn't have to do with stopping someone from publishing something, it has to do instead with holding them accountable after the fact for what they've published. And frankly, yeah, we do need to tighten up a bit because if people think that they have a right to just publish whatever they feel like, regardless of its truth or falsity, then they've clearly taken freedom of speech way beyond what the fact thought about. Even someone as liberal as Thomas Jefferson, in one of his inaugural addresses, said that, you know, truth is a fundamental criterion. The press ought to at least be held to the standard of truthfulness in what they publish. I think uh that's a good reminder for us today.

SPEAKER_01 15:33

Yeah, I mean, and one of the real dangers, of course, is as as you say, I mean, if people cannot deliberate, if people cannot decide their fates, the fates of their communities, the fates of their country, uh with real information. And this is one way, uh, one way in which the the press has let us down. Uh, and uh to see the same thing happening on social media is really, really shocking. And uh we we we it's it's it's kind of a schizophrenia machine, and that's not where American voters ought to be. What are we supposed to derive from the Constitution? How to how to how to protect reputations while allowing for free speech, while enshrining free speech.

SPEAKER_00 16:11

Yeah, I think one thing I'll say in advance is, and I think this is something that people often lose sight of, the founders were of the opinion that reputation is a right, just as much as freedom of speech is a right. Oftentimes, I think in modern cases, uh, the courts will speak about reputational interests. And that kind of weights the scales in a way that's not very helpful to reputation if you think about freedom of speech as a right. Um, we of course know about the founders and John Locke and the rights to life, liberty, and property, but they also thought that a man had, or a woman as well, had a right to their own reputation, especially a justly won reputation. So a libelous publication is really an attack on another person's rights. And that's important to keep in mind for them.

SPEAKER_01 16:53

That's I'm sorry, I I just have to stop for one second. That is so interesting, and it strikes me as so as so important that that in particular, that's a different thing now than it than it was before. The idea that your name, uh, your reputation, your honor, that this is something that belongs to you, and and and this this is this is a right, and this is a very important thing. Sorry, sorry for interrupting. I just wanted to underscore how you know that how important that is.

SPEAKER_00 17:19

I think that is very important. And the older standards were much more protective in part because they valued reputation so much that the kind of the older standard I would say usually presumed that somebody had a good reputation. In other words, if you sued somebody for libel at the time of the founding because they had published something defamatory about you, the court was going to ask them to demonstrate the truth of what they'd said about you, not make you demonstrate the falsity, uh, which is another way of indicating how protective they were of reputation. But to sum up the founder's view about the relationship between libel and freedom of speech and of the press, and how the Sullivan court departed from that, I would say this. The founders thought simply, and they were deriving this from, say, William Blackstone's account of libel and freedom of speech and his commentaries on Amer on English law. And I also would base this on great American jurists like Joseph Story, um, James Wilson, James Kent. I talk about them in the book. These are founding era jurists and commentators on law. Their attitude was that libel is something simply outside the scope of freedom of the press. It's not protected, it is licentiousness of the press. It's a form of license. And so there really is no problem, there's no First Amendment problem if someone sues for libel. And that's what the court in Times versus Sullivan got away from. They treated these libel cases involving public officials and public figures as if they do create a kind of First Amendment problem. They're worried about chilling, a chilling effect on permissible speech. And so then they devised this actual malice doctrine to try to solve the problem that they now perceive. But that problem is one that the founders would not have encountered because they thought across the board, um, if you're a public official or a public figure or a regular person and you're the victim of a defamatory, libelous publication and a false publication, then you should have a right to sue uh to restore your reputation and to get damages for that. So the modern court, as it has done in many cases, has sort of complexified things more than they were for the founders.

SPEAKER_01 19:27

Why were they worried about I mean, this is a phrase we hear all the time, chilling, uh chilling effects on on free speech. Why were they worried about that in particular at that moment?

SPEAKER_00 19:38

Yeah, well, I think at that moment they had a reason to be worried because the Sullivan lawsuit against the New York Times was not the only one. There were several others, maybe many others, coming out of the South. And the Southerners were upset that this Northern kind of liberal newspaper coverage of their segregation and race relations problems were making them look bad. And the Times kind of gave them an opening by publishing something that had factually erroneous matter in it that reflected negatively on the city of Montgomery. So it would be fair, I think, in the context of that particular case, to say that they had a reasonable fear that some people in the South were weaponizing libel law to try to silence criticism of the South. And they didn't want that to happen for reasons that are understandable. However, I think, as Justice Thomas thinks, he said this in one of his concurring opinions, that they could have ruled the way they did in Times versus Sullivan without reconfiguring American libel law. And that would have been the more cautious path. So we I'm sorry, please, yeah. Yeah, I'm just gonna say I don't necessarily have a beef with the outcome of the case, but I have a complaint about the new doctrine that was shoehorned in. Yeah.

SPEAKER_01 20:50

So what you you mentioned Justice Thomas, and and and and you know, and I've heard, and I'm sure some of our our large parts of our audience have heard that Justice Thomas and maybe Justice Gorsuch as well may be willing to uh to look again at uh Sullivan versus the New York Times. So what's what's your why do they want to look at it and do you think that will happen?

SPEAKER_00 21:13

Well, that's a great question. Um I can explain why, and then I'll think about whether I think it will happen. I've done a lot of thinking about that, as you can imagine. So just as Thomas has included some concurring opinions in some libel cases that reached the Supreme Court and that were dealt with fairly summarily, in which he used his opinion to raise a question, to raise an originalist question about the actual malice doctrine, and to say that he thinks it's not really based upon the original understanding, which is what I'm saying too, and to say that he thinks it's a product of just judicial policy making. And some the justices on the court at that time thought that this would be a good standard, so they imposed this standard, even though it didn't really have any roots in older American law. That also, by the way, was the view of justice. Scalia, he said that in an interview before he died that he thought that the judges on the Sullivan Court were just making it up, making up the law. So from a standpoint of a kind of strict originalist, Justice Thomas makes a powerful case. Now we know there are several other justices, the conservative justices on the court, or the recent Republican nominees, that think of themselves as originalists. I think that's true of Justice Gorsuch as well. And he also has ventured a concurring opinion, or it may have been a dissenting opinion in any case, that it didn't ha it did not change the law, but he he used the opinion to make known his view that there is a problem with the actual malice doctrine, and not only on originalist grounds, but maybe in terms of the consequences and the much different media landscape that we have now than we had back in the 1960s.

SPEAKER_01 22:48

So that's um well I was gonna I was gonna ask for you to talk a little bit about the uh about the change media landscape, how you know, about if the court did revisit, uh did revisit this case, what would they be thinking? Uh what would they be thinking in terms of the media landscape, which is which is which is frankly scandalous. I mean, the kinds of stuff that it and it's not just on social media, right? It's not just the stuff on social media, it's how social media is as has seeped into uh regular uh regular mainstream uh press discourse. I mean, we've seen this with any number of things, starting with which I know best Russia gate, of course. I mean, the the insane allegations there. So how how would it uh how could we um how could we help how how would this help shape the the nature of post-social media, post-internet discourse?

SPEAKER_00 23:41

Yeah, I think well let me say one more thing about the originalism question. Since I there are many important recent decisions in which the court uses originalism to correct past errors of the court from an earlier generation when things were more freewheeling, and the justices, frankly, in the 1960s, didn't care much about the original meaning. And I think that's a mistake. So you could say that my book, in a way, is written for a large audience, I hope, but also written with the justices in mind. I want to say to the ones besides Gorsuch and Thomas, if you really believe in originalism, you're going to have to rethink New York Times versus Sullivan. And I think some of them, I hope, will at least be willing to listen to that argument. Um, but another important factor is just what you mentioned, that consequences are different now because the circumstances have changed. Um, generally speaking, and we've seen this in recent cases, such as where the court overturned Roe v. Wade, they're not willing to overturn an old precedent just because it's wrong. They also have to see that it's been harmful in some way. And so I think you can make the case that the actual malice doctrine has been harmful because it makes it so difficult to protect reputation, and it makes it difficult for the American people to have a kind of public discourse in which they can feel confident of the truth of the things that are being promoted by the media on a daily basis. The change here, I think, is that's worth considering is this, or this is one of the changes. I think in the 1960s, the court thought that professional journalists would not publish something injurious to somebody's reputation unless they were pretty certain that it was true, right? And they took a lot of care to make sure that it was true. I'm not so sure that you would say that about the media landscape today, both professional and then unprofessional media. And frankly, the actual malice doctrine gives you a lot of room, if you're a journalist or anybody publishing, to get away with defaming people. Because remember, the standard is you have to demonstrate that they knew it was false or that they acted with reckless disregard for its truth or falsity, which in another case, the court said meant a high degree of knowledge of probable falsity, right? So you're in a situation now where people can publish things that are very injurious to somebody's reputation, like the Russia-Gate stuff that you mentioned. Um, and they're publishing it on the basis of not really knowing that it's true, not even necessarily being able to claim that they think it's probably true. They can put it out there, and as long as there's some kind of mixed judgment in their mind, they'll get away with it. Um, even if they, I mean, one other thing to say about this that might be helpful. I mentioned Justice Brennan earlier. In one of the follow-up cases to New York Times versus Sullivan, he made explicit that mere negligence is a much lower standard than actual malice, which in a way is like saying that if you're a journalist publishing about people, you're allowed to be negligent with their reputation because it's not as bad as knowing that it was false.

SPEAKER_01 26:48

Proving malice, I mean, that's that how do you prove malice? Because you can't see into someone's heart. You have to leave a pretty long trail of evidence, which presumably might be available might be available during the discovery process. But but but but proving malice outside of that, I mean, this is one of the one of the issues I gather, the discovery, um, the the uh Dominion versus Fox case, right? The the trail of evidence, but it's very, very hard to prove. Um, do you think, and I might I I I I'm putting in a position of being Nostradamus here, do you think the court that do you think the the the court will um yeah, do you think the court is going to try to revisit this case?

SPEAKER_00 27:30

I wouldn't say that I think they will revisit it, but I think there's a good shot, or else I wouldn't have written the book. I think at the level of principle, it's very clear to me that a thorough originalist reading of the First Amendment and the history of the development of our understanding of how the First Amendment relates to libel would require you to rethink New York Times versus Solomon. In other words, when Justice Thomas says that that doctrine is just a product of judicial policy making, he's correct. And I think that's demonstrably true. And if I dare to say it, I think I demonstrate it in the book. Um, so you know, there are other justices on the court who are independent thinkers and who have reason to be concerned about this kind of media landscape. So I mean, I'm cautiously optimistic, and of course I'm not the only one making this argument, but I'm cautiously it could take a while, but I'm cautiously optimistic that there will be a rethinking. Whether that will result in a complete reversal, I don't know, but it's worth talking about because it's worth talking about because it's worth getting the constitution right and remaining faithful to the original meaning, and because of the consequences that we've already talked about.

SPEAKER_01 28:42

Reading your book and also following the news, you know, we we we've seen um this uh the uh cash patel, FBI director, is suing the Atlantic for a story that they published. I think he's uh you know suing them for $350 million. So looking at your looking at having your book, having your argument, um, and and as a journalist, I mean, your your book is is is your book to me is really, really important, really, really valuable. Um uh what are the what do you think that this is a a case that might be appealing to the court? I mean, it's it's it's high stakes. I don't I don't know if the $350 million is gonna be part of it, but it's the FBI director, and it's against it's against uh one of America's oldest, most prestigious print publications, The Atlantic. Um so do you do you think that this is something that they would that they might say, okay, yeah, this is a good place to wade in here.

SPEAKER_00 29:39

I think it's a good place to wade in. Of course, it depends on if it's settled or whatever else happens. It that case is a great example of the problems with the existing doctrine. I mean, what the Atlantic published about him is straight up libelous, right? I mean, under traditional understandings of libel, if you publish that somebody's inept and can't do their job or they're drinking on the job, that's damaging to their reputation. So it certainly fits the category. But uh I I I haven't read the entire article, but I think it's based on anonymous sources.

SPEAKER_01 30:09

Yes, there's no there's no one who goes on the record to say, yes, I saw uh director Patel doing this and that. Right. It's it's all it could all be made up in someone's basement.

SPEAKER_00 30:19

Yeah, exactly. And that illustrates the problem of the doctrine, because um the people who published that would have a pretty good defense under the actual malice doctrine because they did have sources. But think about the ridiculous position they're in. They've published something very damaging to another citizen's reputation, and their defense is going to be well, I don't know if it's true or not, but it's um because these guys told us, right? Uh so I mean Patel would have to show that they knew it was false or that they knew that it was probably false, which as you said earlier is very difficult to show. One basic problem with the doctrine is it's it involves that subjective element. It's obviously easier to demonstrate the facts about something than to demonstrate what the people who published were thinking and what they knew. Uh so yeah, I think this would be a good one to rethink.

SPEAKER_01 31:09

That's fantastic. Carson Holloway, thank you so much for being here with us uh today on Roots, Rights, and Reason. And I just want to I I want to again recommend this great your great book to everyone, No Liberty to Libel. The Constitutional Case Against New York Times versus Sullivan. Uh Carson Holloway, thank you. Good uh good luck, good and great luck with your book. Um, it's a fantastic book, really important. It's important for journalists, it's important for readers, it's important for Americans. Um thanks to all of you for watching Roots, Rights, and Reason. We'll see you in our next episode.