I’m obviously not a lawyer, but don’t you have to prove you’ve been damaged? I suspect the NYT can easily produce a thousand surveys of thousands of people who already believe Sarah Palin is a dangerous, hateful, idiot. This article hasn’t changed their beliefs one bit. Conversely, anyone who knows Sarah hasn’t had their beliefs changed either. So really... with which people has she been damaged?
They lied. Period. And their lies directley defamed Palin’s name and character. And they knew it when they printed it.