What is the current state of the law on freedom of speech in the context of a civil rights case?

"[S]hort of accusations of crime or personal dishonesty, the First Amendment protects even sharp attacks on the character, motives, or moral qualifications of 'a public officer or ... active participant in a labor dispute.' " (Okun v. Superior Court (1981) 29 Cal.3d 442, 451, 175 Cal.Rptr. 157, 629 P.2d 1369.) "There is an analogous leeway for criticism of an individual who voluntarily injects himself or herself into public controversy and so becomes a 'public figure.' [Citation.]" (Ibid.)