In the following cases, what is the standard of fault that the plaintiff must prove in order to win the defamation case against the defendant?

a. A national television news report says that the president of the United States is a "philanderer."

b. Dr. Adams is a twenty-five-year-old biologist who teaches at the local community college. He applies for and is given a $1,500 government grant to study whether fleas can understand Italian. A columnist in a local newspaper awards him the "Golden Fleece Award of the Month" for the absurd use of the public funds.