In McDonald v. Smith, 472 U.S. 479 (1985), the plaintiff was a candidate for appointment as a United States Attorney. The defendant sent defamatory letters to various federal governmental officials, including President Reagan, concerning the plaintiff's ethical qualifications to serve as United States Attorney. Based upon those communications, the plaintiff sued for defamation. The defendant argued the Petition Clause of the First Amendment, which guarantees "the right of the people . . . to petition the Government for a redress of grievances," should provide him with absolute immunity. Id. The Court disagreed, noting that "under state common law, damages may be recovered only if the defendant is shown to have acted with malice . . . ." Id. The Court held that requiring plaintiffs to show actual malice was sufficient protection for petitioners, and "the Petition Clause does not require the State to expand this privilege into an absolute one." Id.