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From Aristophanes through Swift and Trudeau, satire has been an important mode of expressing political and social criticism.' Satire is a literary form that employs such devices as sarcasm, irony and ridicule to deride prevailing vices or follies.' It is particularly well-suited for political critique "because it tears down facades, deflates stuffed shirts, and unmasks hypocrisy. . . . Nothing is more thoroughly democratic than to have the high-and-mighty lampooned and spoofed."' As early as 1917, one form of satire, cartoons, was identified as an effective medium for political speech.' But while speech critical of government policies and public figures generally is accorded complete protection under the First Amendment5 as "political speech,"" satire, which is critical of public figures and hence should be protected as political speech,' is not adequately protected against libel claims. Libel is governed by the "actual malice" standard established in New

Protecting Satire against Libel Claims: A New Reading of the First Amendment's Opinion Privilege