It doesn't matter; the Sullivan rule makes it essentially impossible to prove libel against him, no matter how much money he has.
Mr. Schiavo must have almost unlimited resources to pursue this.
The ACLU is working with Mr. Schiavo. There are your "unlimited resources."
The ACLU is helping Mr. Schiavo in his efforts to put down his wife, not with any libel actions. The ACLU, as insane as it is, is not going to help him go after some web sites, etc etc. The ACLU is crazy, but that would require them to contradict half the lawsuits they have going on out there. The ACLU is NEVER going to help Mr. Schiavo with any libel suits.