Then just ask Arsenio Hall, who accused the Beverly Hills NAACP Prez of extortion: Edwards v. Hall, 234 Cal.App.3d 886, 1991 for this analysis:
In public figure defamation case, television personality's references to head of local civil rights organization as an "extortionist," were actionable.
Protection for freedom of speech under California Constitution, which was alleged to be broader than that provided under Federal Constitution, did not prevent allegedly false statements regarding allegedly extortionate statement by head of local civil rights agency to television talk show host from being actionable in public figure defamation case. U.S.C.A. Const.Amend. 1; West's Ann.Cal. Const. Art. 1, § 2(a).