Updated at the bottom to add some thoughts, based on an article written by Hogan’s lawyer after the verdict.
In 1787, “Cincinnatus,” a common nom de plume of anti-federalists, wrote to James Wilson:
It is an easy step from restraining the press to making it place the worst actions of government in so favorable a light, that we may groan under tyranny and oppression without knowing from whence it comes. But you comfort us, by saying,–“there is no reason to suspect so popular a privilege will be neglected.” The wolf, in the fable, said as much to the sheep, when he was persuading them to trust him as their protector, and to dismiss their guardian dogs.
The anti-federalists prevailed on this point, and the First Amendment was born. Continue Reading Hulk Hogan v Gawker Legal FAQ – In Their Lawyers’ Words