The Hearst Corporation publishes the Houston Chronicle, an edition of which included an article headlined "Justice Under Fire." Written by Evan Moore, the article contained pointed criticisms of the Smith County, Texas, criminal justice system. Under the subheading "'Win at all costs' is Smith County's rule, critics claim," the lead article reported that Smith County "is noted for its own brand of justice," which is "driven by aggressive prosecutors who achieve some of the state's longest sentences." The article stated that "critics say Smith County's justice system is tainted and inequitable." It also declared that Smith County prosecutors "have been accused of serious infractions," including "suppressing evidence, encouraging perjury, and practicing selective prosecution." Claiming that the article contained defamatory falsehoods, three Smith County prosecutors named in the article, District Attorney Jack Skeen and two assistant district attorneys, filed a defamation lawsuit against Hearst and Moore. A Texas trial court denied the defendants' motion for summary judgment. The state's intermediate court of appeals affirmed. Hearst and Moore appealed to the Supreme Court of Texas, arguing that they were entitled to summary judgment because, in their view, the plaintiffs could not prove the fault requirement they would have to prove as a constitutional matter in order to win the case. What fault requirement were the defendants referring to in their argument? Were the defendants correct in their contention that they were entitled to summary judgment?