Malice isn't required if the party being defamed is a private figure. See para. 62 of the judgment: "Because the Gibsons were private figures in this libel case

Malice isn't required if the party being defamed is a private figure. See para. 62 of the judgment: "Because the Gibsons were private figures in this libel case, they were required to prove only that Oberlin acted with negligence, not actual malice."