"A distinction between criticism and defamation is, that criticism deals only with such things as invite public attention or call for public comment, and does not follow a man into his private life, or pry into his domestic concerns. It never attacks the individual, but only his work. A criticism of a public man, consisting of imputations upon his motives, which arise fairly and legitimately out of his conduct, is generally regarded as justifiable."
Eugene Ambrose Philbin was an American lawyer and politician from New York. He was New York County District Attorney from 1900 to 1901 and later served as a justice on the New York Supreme Court.