The United States Supreme Court has held that private figure plaintiff alleging defamation has the burden of proving falsity of media defendant's speech on matters of public concern.
Philadelphia Newspapers, Inc. v. Hepps, 106 S.Ct. 1558 (1986).
Constitutional Law - First Amendment - Defamation - Libel,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol25/iss4/9