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. brought public figure defamation claims squarely in line with the modern pleading standards set forth in the Supreme Court’s Ashcroft v. Iqbal and Bell Atlantic Corp. v. Twombly decisions.
