Curtis Publishing Co. v. Butts, 388 U.S. 130 (1967)
If I were to say:
“Mr. Trump eats the heads off babies”
Or
“Mr. Brilliant eats the head off babies”
I could be sued for libel for the bottom statement and not the top. The statement is patently false in both cases, but because Trump is a public figure it is deemed free speech. Just because he’s a public figure doesnt mean it damages him any less. You could probably argue, in fact, it may damage him more. This is what he is getting at.
I don’t nessasarily agree, but he kind of has a point.