Public figure defamation rules

1. When independently reviewing a jury verdict on actual malice under Bose Corp. v. Consumers Union of United States, Inc. or Harte-Hanks Communications, Inc., can a court of appeals substitute its own contrary findings concerning the defendant’s subjective knowledge or intent under the reexamination clause of the Seventh Amendment of the United States Constitution? 2. Whether, under New York Times Co. v. Sullivan, 376 U.S. 254 (1964), and Masson v. New Yorker Magazine, Inc., 501 U.S. 496 (1991), a public-figure plaintiff who proves that a publisher deliberately assembled accurate excerpts into a materially false defamatory message must separately prove a subjective intent to communicate the resulting implication, or whether the publisher’s knowledge of the source material and deliberate construction of the message are evaluated as evidence that it knew or recklessly disregarded the falsity of the message it published. 3. Alternatively, whether the Court should reconsider New York Times Co. v. Sullivan, 376 U.S. 254 (1964), and its progeny, to determine whether the First Amendment permits States to apply ordinary common-law rules to public-figure defamation claims without requiring proof of actual malice.