In 1964, the quarterly magazine Fact published an issue entitled “The Unconscious of a Conservative: A Special Issue on the Mind of Barry Goldwater” where they openly criticized the Senator from Arizona and 1964 presidential candidate. The editor and publisher of Fact, Ralph Ginzburg, polled over 1,800 psychiatrists, and more than half of the respondents said that they considered Goldwater to be mentally unfit to assume the presidency.
The then Medical Director of the American Psychiatric Association, Walter E. Barton, sent a warning to Ginzburg about this issue of his magazine, stating, “a psychiatrist’s evaluation must take place in the context of a doctor-patient relationship and a thorough clinical examination”. Goldwater would go on to sue the magazine for “false, scandalous and defamatory statements referring to and concerning [the] plaintiff.”