With bar associations and other legal organizations rightly railing against the former president's bashing of judges, we hope that such railing does not drown any legitimate criticisms of judges, or their First Amendment Protections. When lawyers do criticize judges, they place themselves in a precarious position. Rule of Professional Conduct 8.2(a) provides "[a] lawyer shall not knowingly make a false statement of fact concerning the qualifications, conduct or integrity of a judge." This rule embodies the New York Times v. Sullivan standard of "actual malice" that applies to defamation claims by public officials.