New York Times Co. v. Sullivan
Held: A State cannot, under the First and Fourteenth Amendments, award damages to a public official for defamatory falsehood relating to his official conduct unless he proves "actual malice" -- that the statement was made with knowledge of its falsity or with reckless disregard of whether it was true or false. Pp. 265-292.
https://www.law.cornell.edu/supremecourt/text/376/254
unless he proves "actual malice" -- that the statement was made with knowledge of its falsity or with reckless disregard of whether it was true or false
Where in that legal definition of "actual malice" do you find anything about ill will?
The only reason I point out that "actual malice" in defamation law has nothing to do with ill will, is that most people see the word "malice" and think "ill will." But the law is not encumbered with following the usual dictionary.
At any rate, I agree that "actual malice" must be proven (in a defamation case brought by a public figure), but "actual malice" under the peculiar definition that applies in defamation cases -- where "actual malice" has nothing at all to do with ill will.