In 2001, someone sent letters laced with anthrax to members of Congress and news organizations. The individuals who handled the mail died from contact with the anthrax. Throughout the subsequent months, an editorial columnist for The New York Times, named Nicholas Kristof, wrote a series of articles that implicated a biodefense research scientist named Dr. Steven J. Hatfill as a suspect in the anthrax attacks. When the articles were written, the FBI had indicated that it considered Hatfill a suspect, but had not arrested him. In his final article, Kristof demanded that the FBI either exculpate or arrest Hatfill. Hatfill filed suit against the New York Times Company, alleging that the articles were defamatory in that reasonable readers would assume that Hatfill had actually committed the crimes. The district court granted the defendant’s motion for summary judgment. Hatfill appealed. Is Hatfill required to show actual malice? If so, can he succeed on his defamation claim? Hatfill v. The New York Times Co., 532 F.3d 312 (4th Cir. 2008).