Harassment was not at issue. The jury found malice because they had to if they wanted to impose any damages at all. For a public figure—such as a public employe

Harassment was not at issue. The jury found malice because they had to if they wanted to impose any damages at all. For a public figure—such as a public employee in the news—the "actual malice" standard applies in defamation cases in the U.S. I'm glossing over a bit of nuance regarding limited public figures, without which I'm not sure this would apply to Mann (I'm not a 1A practitioner), but Wikipedia does a pretty good job of discussing the cornerstone case and further developments, for those interested. https://en.m.wikipedia.org/wiki/New_York_Times_Co._v._Sullivan https://en.m.wikipedia.org/wiki/New_York_Times_Co._v._Sulliv...