This paper contains an analysis of Justice William Brennan's Supreme Court opinions concerning cases on freedom of expression and his interpretations of Alexander Meiklejohn's theory of actual malice in cases of libel. Particular attention is paid to Brennan's landmark contribution to the law of libel, his opinion in "New York Times v. Sullivan," and analytical criticism of this opinion. Later cases are examined to determine any changes in Brennan's interpretation of actual malice, as well as to examine the impact of his "libel formula" on a narrowing view of public issue and public official defamation. The concluding section of the paper indicates that Brennan's history of using Meiklejohnian theory demonstrates the difficulties inherent in the theory and why it has failed. (RL)