NYT v. Sullivan? And even 0’s not that stoopid: The first thing a defendant would do is hit him with a subpoena duces tecum and the State of Hawaii with a 3rd Party Request for Production.
Thats the point... he’s not even going to bother trying to sue even if the statements were false. I think Rush would only state true statements on the issue because of ratings and credibility though, not fear of lawsuits