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The Chances of Suspension for Reporting Negative Things
There are some members of the current Supreme Court that have openly expressed their hostility to this principle and think that it should be easier to sue the media for saying negative things or making somewhat small errors. It's really hard to clear the bar of reckless disregard than the malice standard of New York Times, but if ever a news outlet did it, it was Fox News because they knew they knew the people they were about to put on air were going to lie.