Quite right. I should have been more clear: Criminal libel laws may still be in the statute books, much like laws may still exist requiring someone carrying a red flag to walk in front of horseless carriages. But we should expect prosecutions under criminal libel laws to fail because of the modern interpretation of the First Amendment (and state constitutional protections that may be broader).
For instance a court in the 1990s struck down Montana's criminal libel law as unconstitutional: https://casetext.com/case/state-v-helfrich-1 But as far as I know it is still on the books.
For instance a court in the 1990s struck down Montana's criminal libel law as unconstitutional: https://casetext.com/case/state-v-helfrich-1 But as far as I know it is still on the books.