In 1964, the magazine Fact published the article "The Unconscious of a Conservative: A Special Issue on the Mind of Barry Goldwater." The article included the results of a poll among psychiatrists questioning them if Sen. Barry Goldwater, the Republican presidential candidate, was fit to be president. Of the 2,147 who responded, 657 said that he was fit and 1,189 said that he was not.
In addition to the responses to the question about Goldwater, the article included a series of quotations from the respondents, various facts and observations about Goldwater. Goldwater sued the editor-publisher of the magazine, Ralph Ginzburg, who had edited some of the quotations from articles and even from some of the psychiatrists interviewed, and won $75,000 in damages, since the judge found that Ginzburg had acted with malicious intent.
Before the publication of the article, the medical director of the American Psychiatric Association had warned Ginzburg that the responses were not valid without a "thorough clinical examination" of Goldwater, according to Jonathan D. Moreno, an American philosopher and historian.