In Associated Press v. Walker, 388 U.S. 130 (1967), the trial court had granted judgment notwithstanding a jury verdict for punitive damages on the ground that the evidence supported a finding of no more than ordinary negligence on the defendant's part. Id. Both the Court of Appeals and the Supreme Court affirmed, the latter undertaking "to face for themselves the question whether there is sufficient evidence to support the finding" of actual malice. (Id. at 158, 87 S.Ct. at 1993.)