In Time, Inc. v. Firestone, 424 U.S. 448 (1976), the court held that Mrs. Firestone, although a socialite of Palm Beach and the wife of a member of a famous family, was not and did not become a public figure, even though her divorce proceedings had become publicized and well known. Plaintiff herself caused some of the publicity by the calling of a series of press conferences. The 17-month trial attracted national attention and elicited 88 articles in the Miami and Palm Beach newspapers. Even so, the United States Supreme Court held that the relevant inquiry should be confined to whether a plaintiff is a public officer or a public figure who might be assumed to voluntarily expose himself to increased risk of injury from a defamatory falsehood. The court explained: "Respondent did not assume any role of especial prominence in the affairs of society, other than perhaps Palm Beach society, and she did not thrust herself to the forefront of any particular public controversy in order to influence the resolution of the issues involved in it." ( Id. at pp. 453-454.) The U.S. Supreme Court did not apply the New York Times v. Sullivan, 376 U.S. 254 (1964) actual malice test because the plaintiff was not a public figure. Time, Inc., 424 U.S. at 454-55. After refusing to apply the actual malice standard, the Supreme Court flatly rejected Time's argument that Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974) did not permit a recovery for mental anguish damages, because, according to Time, "the only compensable injury in a defamation case is that which may be done to one's reputation." Time, Inc., 424 U.S. at 460. The Supreme Court stated: "In Gertz we made it clear that States could base awards on elements other than injury to reputation, specifically listing 'personal humiliation, and mental anguish and suffering' as examples of injuries which might be compensated consistently with the Constitution upon a showing of fault." Time, Inc., 424 U.S. at 460.