Do any of you know of arguments that New York Times v. Sullivan departed from the original understanding of the freedom of speech and of the press as to state action (as opposed to whether broad libel liability was constitutionally permissible state action)?

I'm looking for claims that the Framers understood the freedom of speech and of the press as not applicable to civil damages liability, at least under common-law torts. I should note that my sense is that this historical claim is mistaken -- but I'm just looking for evidence of it. Many thanks!