Filed an amicus brief (with other amici) in the Supreme Court of the State of Idaho in Verity v. USA TODAY. The brief urges the court not to recognize a cause of action for “defamation by implication” based on the dissemination of concededly accurate facts about a matter of public concern. The case involves a schoolteacher whose license had been revoked for misconduct in one state but later issued in another state. Recognizing implied defamation as a cause of action would run afoul of the First Amendment because speech would inevitably be inhibited out of fear that its dissemination would lead to liability. [2018]