Any written or printed article which is false and is conveyed by publication to third parties is defamatory or "libelous." That is, it is actionable if it tends to subject the plaintiff to hatred, scorn, ridicule, public contempt or disgrace; or if it induces a substantial number of respectable community members to avoid, shun, or deprive him of their friendly association, even though the defamation imputes no moral turpitude to him. Despite a long history of judicial decisions and numerous discussions and writings by the legal profession, there are few areas of the law so unsettled as the law of libel.
Richard Szilagyi, How Far May Newspapers Go in Criticizing, 17 Clev.-Marshall L. Rev. 283 (1968)