Question: Did the New York Times Co. v. Sullivan case or Dusky v. United States come first?
Context: New York Times Co. v. Sullivan, 376 U.S. 254 (1964), was a landmark United States Supreme Court case that established the actual malice standard, which has to be met before press reports about public officials can be considered to be defamation and libel; and hence allowed free reporting of the civil rights campaigns in the southern United States.  It is one of the key decisions supporting the freedom of the press.  The actual malice standard requires that the plaintiff in a defamation or libel case, if he is a public figure, prove that the publisher of the statement in question knew that the statement was false or acted in reckless disregard of its truth or falsity.  Because of the extremely high burden of proof on the plaintiff, and the difficulty of proving the defendant's knowledge and intentions, such claims by public figures rarely prevail. Banamex v. Narco News, 2001 603429/00, was a New York Supreme Court case that extended the findings of New York Times Co. v. Sullivan, that freedom of the press applied to an online newspaper's reporting. Cornelius Mahoney "Neil" Sheehan (born October 27, 1936) is an American journalist.  As a reporter for "The New York Times" in 1971, Sheehan obtained the classified Pentagon Papers from Daniel Ellsberg.  His series of articles revealed a secret United States Department of Defense history of the Vietnam War and led to a US Supreme Court case, "New York Times Co. v. United States" (403 U.S. 713), when the United States government unsuccessfully attempted to halt publication. Dusky v. United States, 362 U.S. 402 (1960) , was a landmark United States Supreme Court case in which the Court affirmed a defendant's right to have a competency evaluation before proceeding to trial.  The Court outlined the basic standards for determining competency. Heed Their Rising Voices is a 1960 newspaper advertisement published in the "New York Times".  It was published on March 29, 1960 and paid for by the "Committee to Defend Martin Luther King and the Struggle for Freedom in the South".  The purpose of the advertisement was to draw attention and support towards Martin Luther King Jr. A recent felony charge of perjury was leveled against him and could have resulted in a lengthy imprisonment.  The headline of the advertisement was drawn from a phrase used in the "New York Times" editorial, "Amendment XV", published on March 19, 1960.  The advertisement became the source of a libel suit in the United States Supreme Court case "New York Times Co. v. Sullivan" (1964). Freedom for the Thought That We Hate: A Biography of the First Amendment is a 2007 non-fiction book by journalist Anthony Lewis about freedom of speech, freedom of the press, freedom of thought, and the First Amendment to the United States Constitution.  The book starts by quoting the First Amendment, which prohibits the U.S. Congress from creating legislation which limits free speech or freedom of the press.  Lewis traces the evolution of civil liberties in the U.S. through key historical events.  He provides an overview of important free speech case law, including U.S. Supreme Court opinions in "Schenck v. United States" (1919), "Whitney v. California" (1927), "United States v. Schwimmer" (1929), "New York Times Co. v. Sullivan" (1964), and "New York Times Co. v. United States" (1971). The origins of the United States' defamation laws pre-date the American Revolution; one influential case in 1734 involved John Peter Zenger and established precedent that "The Truth" is an absolute defense against charges of libel.  (Previous English defamation law had not provided this guarantee.)  Though the First Amendment of the U.S. Constitution was designed to protect freedom of the press, for most of the history of the United States, the U.S. Supreme Court failed to use it to rule on libel cases.  This left libel laws, based upon the traditional "Common Law" of defamation inherited from the English legal system, mixed across the states.  The 1964 case "New York Times Co. v. Sullivan", however, radically changed the nature of libel law in the United States by establishing that public officials could win a suit for libel only when they could prove the media outlet in question knew either that the information was wholly and patently false or that it was published "with reckless disregard of whether it was false or not".  Later Supreme Court cases barred strict liability for libel and forbid libel claims for statements that are so ridiculous as to be patently false.  Recent cases have added precedent on defamation law and the Internet. Harte-Hanks Communications Inc. v. Connaughton, 491 U.S. 657(1989), was a case in which the Supreme Court of the United States supplied an additional journalistic behavior that constitutes actual malice as first discussed in "New York Times Co. v. Sullivan" (1964).  In the case, the Court held that departure from responsible reporting and unreasonable reporting conduct alone were not sufficient to award a public figure damages in a libel case.  However, the Court also ruled that if reporters wrote with reckless disregard for the truth, which included ignoring obvious sources for their report, plaintiffs could be awarded compensatory damages on the grounds of actual malice. New York Times Co. v. United States, 403 U.S. 713 (1971), was a landmark decision by the United States Supreme Court on the First Amendment.  The ruling made it possible for "The New York Times" and "The Washington Post" newspapers to publish the then-classified "Pentagon Papers" without risk of government censorship or punishment. Milkovich v. Lorain Journal Co., 497 U.S. 1 (1990), was a United States Supreme Court case that rejected the argument that a separate opinion privilege existed against libel.  It was seen by legal commentators as the end of an era that began with "New York Times Co. v. Sullivan" and continued with "Gertz v. Robert Welch, Inc.", in which the court clarified and greatly expanded the range and scope of what could be said in the press without fear of litigation.
Answer: Dusky v. United States