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Biro v. Condé Nast: The “Plausibility” of Actual Malice Allegations in Public-Figure Defamation Cases

By Scott J. Sholder December 11, 2015

On Tuesday the U.S. Court of Appeals for the Second Circuit held that public-figure plaintiffs in defamation cases must set forth plausible allegations, at the pleadings stage, that media defendants acted with actual malice.  Heralded as a victory for the media industry and First Amendment rights, the court in Biro v. Condé Nast, et al.

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