A showing of actual [[malice]] requires proof that the defendant knew that his statement was false or spoke with reckless disregard for whether it was false or not.<ref>376 U.S. at 279-80.</ref> | A showing of actual [[malice]] requires proof that the defendant knew that his statement was false or spoke with reckless disregard for whether it was false or not.<ref>376 U.S. at 279-80.</ref> |