The public figure has to prove all of these points... and that the defendant acted in reckless disregard for the truth. (nakedpastor.com)
@TonySnow The main issue in both cases would be whether the site expressly or by implication conveys the impression that the convictions have not be expunged when they actually have, through negligence in ignoring notice given, or through reckless disregard for the truth in the case of defamation. (law.stackexchange.com)
He did not decide whether Michael Mann had any evidence to support his claim that Steyn acted with reckless disregard for the truth. (steynonline.com)