For 10 points, name this printing of offensive, untrue content.
The Massachusetts Supreme Court upheld the common law definition of this offense in the 1808 case Commonwealth v. Clap, citing its "direct tendency to a breach of the public peace." Canada similarly maintained the common law's placing the burden of disproving this offense on the defendant in Grant v. Torstar Corp. A piece entitled "Heed Their Rising Voices" touched off a Supreme Court case which ruled that this offense required (*) "actual malice," denying damages to a namesake public safety commissioner in Montgomery. Andrew Hamilton defended a man accused of it because he had criticized William Crosby. John Peter Zenger was put on trial for this offense, for which New York Times Co. v. Sullivan carved out "public figure" exemptions. For 10 points, name this printing of offensive, untrue content.
The Massachusetts Supreme Court upheld the common law definition of this offense in the 1808 case Commonwealth v. Clap, citing its "direct tendency to a breach of the public peace.
libel [or defamation or word forms of either; do not accept or prompt on "slander"]