Reposted by Aditya Iyer 🍉
Aditya Iyer 🍉
@adityahere.bsky.social
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He/Him. Independent journalist who writes mostly about culture, history, and politics. Words all over the place. Immigrant Londoner. My work here: authory.com/AdityaIyer. @Thatadityaiyer over at the other place.
![The Complaint also alleges that President Trump told Defendants that the Letter was a fake
before they ran the Article. President Trump argues that this allegation shows that Defendants
acted with serious doubts about the truth of their reporting and, therefore, with actual malice. The
Court disagrees. To establish actual malice, “a plaintiff must show the defendant deliberately
avoided investigating the veracity of the statement in order to evade learning the truth.” Reed, 2025
WL 1874638, at *3. The Complaint comes nowhere close to this standard. Quite the opposite. The
Article explains that, before running the story, Defendants contacted President Trump, Justice
Department officials, and the FBI for comment. President Trump responded with his denial, the
Justice Department did not respond at all, and the FBI declined to comment. In short, the
Complaint and Article confirm that Defendants attempted to investigate. The Article also states
that the WSJ reviewed the Letter. [ECF No. 35-2].13 Accordingly, President Trump’s conclusory
allegation that Defendants had contradictory evidence and failed to investigate is rebutted by the
Article and is insufficient to establish actual malice. See Michel, 816 F.3d at 704 (holding that
plaintiff did not adequately allege malice where record “indicate[d] that the reporters conducted
some outreach and engaged in due diligence”).14
13 The Complaint alleges that the Article does not explain, among other things, whether Defenda](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:svawqo4jxobyyuqmixplvcux/bafkreihuydsux6rkwa4efdnydg6su2quqdxhdcycnaoeg5reio5iq7dlcm)
