In Hustler Magazine, Inc. v. Falwell (1988) 485 U.S. 46, Jerry Falwell sued Hustler Magazine and Larry Flynt after discovering that the magazine had featured a parody that insinuated that Falwell's "first time" was "during a drunken incestuous rendezvous with his mother in an outhouse." In Falwell, the Supreme Court attempted to strike a balance between allowing the free flow of ideas and protecting a public figure from defamatory falsehoods. A public figure or public official often will face criticism. "Such criticism, inevitably, will not always be reasoned or moderate; public figures as well as public officials will be subject to 'vehement, caustic, and sometimes unpleasantly sharp attacks' ." Nevertheless, free speech demands "breathing space." Such breathing space requires an objective standard of measuring constitutionally acceptable speech, rather than a subjective standard based on what society finds as outrageous or offensive. The court concluded that a public figure or public official must show that the publication contains a false statement of fact that was made with actual malice. In applying this standard, the court accepted the jury's finding that the parody could not reasonably be understood as describing actual facts concerning the renowned reverend. Even where the publication was patently offensive and deliberately made to inflict emotional injury, it was protected under the First Amendment guarantee of free speech.