Defamation: Recent Developments in the Interpretation of Malice

action actual malice alleged Amant Amendment Atlas attorney banc believed called Chapter charges Circuit clear common Comnas concern conclusions conduct considered Constitution Court of Appeals criticism damages decision defamation defamatory defendant entertained serious definition denied determine editorial entertained serious doubts evidence examined expression fact failed false falsity favor federal finding freedom Ibid included indicators individual interest investigation involved issues Journal journalists judge jury Justice knew knowledge libel Liberty litigation March matter media defendants memo newspaper noted opinion organizations panel percent plaintiffs police Post present prevailed protection prove public officials public person plaintiffs published question reason reckless disregard record regarding reliable remanded reporter reporter's reputation resolution Review rule sources speech standard statements story successful suit summary judgment Supreme Court Tavoulareas told trial truth U.S. Supreme Court University writer wrote York