Called libel by omission or libel by implication, cases like Mohrs received their biggest boost in 1990, when the U.S. Supreme Court held in Milkovich v. Lorain Journal that a newspaper columnist could be liable for implying that a witness lied in a judicial proceeding. Rejecting the newspapers argument that expressions of opinion never could be the basis for a libel suit, the court held that the dispositive question is whether a reasonable factfinder could conclude that statements in the article implied a verifiably false statement of fact about the plaintiff. If so, the court said, the First Amendment would not protect the article from a libel action.Link
Thanks for the clarification.
The case itself sounds very familiar.