Palin v. The New York Times Co.
United States District Court for the Southern District of New York
264 F.Supp.3d 527 (2017)
After a 2017 congressional-baseball-game shooting, Times editor Bennet rewrote a staff editorial to assert a "clear" and "direct" link between a 2011 SarahPAC electoral map and the earlier Loughner shooting of Gabby Giffords, even though media reports (including a linked ABC article Bennet never actually read) had found no such connection; the Times corrected the piece the next day, but Palin (plaintiff) sued for libel, and the Times (defendant) moved to dismiss for failure to plausibly allege the elements a public figure must show.
Whether libel of a public figure requires publication of a defamatory statement made with actual knowledge or reckless disregard of its falsity.