Participated in an amicus brief (with the Reporters Committee and other amici) filed with the New York Appellate Division, First Department, in Rainbow v. WPIX. The case involved a media outlet that misidentified a public school teacher accused of bullying. The teacher, Starlight Rainbow, appealed after the trial court ruled in favor of the media defendant. The brief argued that the gross irresponsibility standard at issue should be reaffirmed, not weakened. This standard appropriately balances the need for accuracy with the practical realities of the news business. For reporters to inform the public about matters of concern, they must be protected from excessive defamation liability. The brief urged the court to affirm the lower court ruling in favor of the media outlet.