One of the basic principles of civil law is that a plaintiff must demonstrate harm in order to have any legal standing to pursue a civil lawsuit. I’m not sure Sarah Palin would ever be able to prove that she suffered any harm in this case even if the NYT came out and admitted that they deliberately lied about her.
The Sullivan ruling (c.1960) I believe raises its ugly head once more. A decision made by lawyers who wouldn’t know their @sses from holes in the ground.