Where the statement published is such that its defamatory potential was apparent to a reasonably prudent person, the plaintiff must show that the defendant permitted the false statement to appear, if not through actual malice, at least through negligence as to its truth or falsity Although at common law defamation liability could be strict, a number of Supreme Court decisions based on the First Amendment now impose a fault requirement in cases involving public figures or matters of public concern. The degree of fault to be established depends on the type of plaintiff, i.e., whether he is a public official or public figure as compared with a private person involved in a matter of public concern.