AFAIK, the standard is still ‘reckless disregard as to the truth or falsity’, even for a public person. I’d guess there must be law or case law that has made ‘reckless disregard’ meaningless.
‘Free speech’ original intent meant one was free to criticize the government, even in outlandish ways. The Founders would have laughed at the idea that it applied to pornography, for example.
Granted, the degenerate porn seen today was not contemplated by the founders as protected free speech.
However, I often think of Benjamin Franklin in France successfully convincing the French to help our fledgling nation.
Ben was reputed to be quite the man about town in libertine France....and enjoyed all of the pleasures France had to offer.
Perhaps he brought back souvenirs of licentious France?