Samantha S. Barbas, a law professor at the University of Iowa and the author of a book about the Sullivan case, “Actual Malice,” said Ms. Palin’s loss would “fuel the momentum to overturn the New York Times v. Sullivan standard as it applies to public figures” because it showed how hard it was for plaintiffs to clear the actual malice threshold.

It was Palin's second defeat in an attempt to hold the New York Times accountable for what she said was defamation from a 2017 editorial.

A jury has concluded The New York Times did not libel former Alaska Gov. Sarah Palin in a 2017 editorial she says damaged her reputation.