A Third Circuit ruling in a libel suit involving a Virgin Islands judge and a newspaper illustrates at least this much: It's a lot more difficult to prove that a journalist recklessly disregarded the truth in cases that hinge on what is being insinuated, not spelled out.
Source: http://blogs.wsj.com/law/2013/03/08/third-circuit-tackles-libel-by-insinuation/?mod=WSJBlog
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