93. Newspaper, a local paper in the town of Chippewa, publishes an article called “Police Blotter” in every day’s paper. The Blotter purports to be a reprinting of crimes handled by the local police (and listed on the police department’s blotter) the prior day. In one edition, the Blotter article says, “John Smith was charged by the police with a burglary at 123 Main Street, at the home of John Brown.” In fact, this item has not been taken from the blotter, but is the result of a conversation between the cub reporter on the police beat and Officer Flatfoot of the Chippewa Police Dept. Because the reporter was inexperienced and tired, the article as printed reversed the names — it was really John Brown who was charged with a burglary at the home of John Smith at 123 Main. A reporter of average professional standards would have read his notes back to Flatfoot before leaving the police department, but the cub reporter did not know to do this. Neither the reporter nor Newspaper or any of its other employees knew that the item printed was false. John Smith, a local resident of no special prominence, brings a libel action against Newspaper. May he recover?