It (usually) takes a lot more than being called a "criminal" to win a judgment for defamation per se. Insults usually don't apply.
"John is a criminal" usually gets dismissed.
"John assaulted a photographer" is another matter. If that was the judges decision, I'd have a different opinion on this case unless there's reasonable belief on the part of the publisher that this individual did that.
Like robbery, assault and battery?