Chapadeau v. Utica Observer-Dispatch, 38 NY2d 196, 198, 341 N.E.2d 569, 379 N.Y.S.2d 61 (1975) involved a defamation action brought by a public school teacher who challenged the accuracy of a newspaper account of his arrest for unlawful possession of a hypodermic needle and heroin. In Chapadeau, the Court of Appeals outlined the history of libel law jurisprudence in New York State, citing "the landmark decision" in New York Times Co. v. Sullivan, which "brought the law of libel within the ambit of the constitutional protections" of the First Amendment by holding that "a public official cannot recover for a defamatory statement about his official conduct in the absence of proof of malice." The Chapadeau court described how the constitutional privilege was extended "to publishers of libelous statements concerning private individuals who are involved in matters of public interest". In applying the precedent, the court in Chapadeau reasoned that where the content of the article is arguably within the sphere of legitimate public concern, which is reasonably related to matters warranting public exposition, the party defamed may recover; however to warrant such recovery he must establish, by a preponderance of evidence, that the publisher acted in a grossly irresponsible manner without due consideration for the standards of information gathering and dissemination ordinarily followed by responsible parties. 38 NY2d at 199. Examining the "nature of the offending communication", the Chapadeau court found that the article concerning the arrest of Chapadeau, a public school teacher, for felony possession of heroin and unlawful possession of a hypodermic needle fell "within the sphere of public concern". It held that the fact of Chapadeau's occupation, which involved instructing youth, coupled with the issue of heroin addiction clearly established the information in the article as matters of public concern.