Sarah may be limited by NYT v Sullivan, but Todd sure isn’t.
Well, maybe Todd is a “limited person public figure” or something. But it really shouldn’t matter, because if publishing something defamatory as a fact (and not in a parody) when you know that there is no evidence of its truthfulness isn’t “actual malice,” I don’t know what is. If I remember NYT v. Sullivan correctly, the plaintiff doesn’t need to prove that the author *knew* that what he published was false, he or she needs to show that the author had reckless disregard for whether or not it was true.