Participated in an amicus brief (with other amici) filed with the U.S. Court of Appeals for the Sixth Circuit in Croce v. New York Times Co. The case involved a defamation claim brought by cancer researcher and professor Carlo M. Croce, M.D., against the New York Times. The amicus brief focused on the “balanced report” rule and innocent construction analysis. It argued that science reporting often includes stories about controversies and claims of misconduct or inaccuracy, and that the news media must be able to report on these matters without fear of defamation liability. The brief urged the appellate court to uphold the district court’s dismissal of the defamation claim, noting that the district court had correctly applied the innocent construction rule.