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Brennan's invocation of Meiklejohn's theory in the Sullivan case has turned out to be largelv in vain as a means of protecting 'cherished values encased in the First Amendment.'If .... the same verbal attack is made in order to show unfitness of a candidateforgovernmental office, the act is properly regarded as a citizen's participation in government. It is, therefore, protected by the First Amendment. And the same principle holds good if acitizcn attacks. by words of disapproval and condemnation, the policies of thegovernment. oreven the structures of the Constitution. These are "public" issues concerning which, under our form of government. he has authority, and is assumed to have competence to judge. Though private libel is subjecr ro legislative conhol. political or seditious libel is not. (Emphasis' added).'The author is professor ofjournalism and mascommunication at Minnesota. This article is an abridgement of a Howard R. Marsh ICCIUI-C presented at the University of Michigan April 25. 1980.