As discussed above, in some types of libel suits — those involving libel per quod and trade libel — plaintiffs must prove monetary loss in order to win. In most libel suits, however, injury need not be tangible. The more common types of harm libel plaintiffs allege include “impairment of reputation and standing in the community, personal humiliation, and mental anguish and suffering.” The U.S. Supreme Court has said a libel plaintiff must prove injury to win, unless he or she is able to prove actual malice, which is discussed below.
Generally, the injury requirement is not a key issue in libel suits. In most cases, it is not difficult for a plaintiff to convince a court that a news article accusing him of committing a crime, taking a bribe or engaging in unethical business practices hurt his reputation. However, it is important to remember that mere hurt feelings or embarrassment is not enough for a libel suit to succeed. As the N.C. Supreme Court said in 1938, “The law seeks to compensate for damage to the person, the reputation or the property of an individual. It cannot and does not undertake to compensate for mere hurt or embarrassment alone.” The type and degree of harm the plaintiff suffered are related to the damages ultimately awarded the successful libel plaintiff. Damages are discussed briefly below.
 Gertz v. Robert Welch, Inc., 418 U.S. 323, 350 (1974).
 Flake v. Greensboro News Co., 212 N.C. at 788.