NYT v. Sullivan presumes a media that is acting in good faith. Here I assume that it can be demonstrated the NYT and WaPo intentionally fabricated stories without any basis. I don’t think Sullivan should apply to such facts.
Even if President Trump loses he wins. The WaPo are going to be forced to admit “The Posts claims were false statements of fact, and were published with actual malice or reckless disregard for the truth”, which clearly was the case.