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Falwell, which affirms parody and satire as protected speech and sprang from the Sullivan decision.

Falwell began recounting to various audiences and political rallies across the country how he had asked Carter why “practicing homosexuals” served on the White House staff.

Carter, according to Falwell, replied, “I am president of all the American people and I believe I should represent everyone.”

Falwell’s rejoinder: “Why don’t you have some murderers and bank robbers and so forth to represent?”

Falwell, in fact, had fabricated the entire exchange in an apparent attempt to discredit Carter in the eyes of evangelicals.