“…CHAFEE, supra note 40, at 22. Donald Gillmor and Melanie Grant adopt an even more extreme position and contend that civil libel's rare 233 and "now generally discouraged," 234 and criminal libel statutes as "mostly dormant," 235 "not a real problem," 236 "no longer … a serious risk," 237 "obsolete legal action[s]," 238 which have "largely fallen into disuse," 239 "relics of the past," 240 "not yet buried," 241 and "like the vampire legend [which] never quite seems to die out." 242 Yet more than a decade before the 1964 Supreme Court decision in Garrison, scholars also described criminal libel statutes as latent 243 and libel actions as "almost obsolete action," 244 and prosecutions for the crime as rare 245 or unusual.…”