IANAL but I believe Larry Flynt's case only established that a public figure can not be awarded damages for "emotional distress" caused by hurtful remarks done

IANAL but I believe Larry Flynt's case only established that a public figure can not be awarded damages for "emotional distress" caused by hurtful remarks done in satire or parody. I do not believe that affords protection from libel should the criteria for libel be met (which, as others have pointed out, is quite difficult to prove).