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Defamation cases are hard to win in the United States. Starting with its 1964 ruling in New York Times v. Sullivan, the Supreme Court has required plaintiffs to meet a very high threshold of proof before American courts can hold someone liable for defamation. Whether something is simply false is insufficient; the justices have held that the allegedly defamatory material must be distributed with a “reckless disregard” for the truth.Anything less than that would violate the First Amendment’s guara

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