From recent cases from Ken Ditkowsky:

Garrison v. State of LA

Where criticism of public officials is concerned, we see no merit in the argument that criminal libel statutes serve interests distinct from those secured by civil libel laws, and therefore should not be subject to the same limitations.3 At common law, truth was no defense to criminal *68 libel. Although the victim of a true but defamatory publication might not have been unjustly damaged in reputation by the libel, the speaker was still
punishable since the remedy was designed to avert the possibility that the utterance would provoke an enraged victim to a breach of peace. That argument is well stated in Edward Livingston’s explanation of the defamation provisions of his proposed penal code for Louisiana:

‘In most cases, the connexion between cause and effect exists between the subject of this chapter and that of a subsequent one—Of Duels…