crosshairs against the congressional districts held by 20 Democrats, including Giffords. The Times later issued a correction stating that "no such link was established" between the advertisement and the shooting and clarifying that what was depicted in the crosshairs in the ads were "electoral districts, not individual Democratic lawmakers." The Times wrote that the error did not "undercut or weaken the argument of the piece." In subsequent testimony at an evidentiary hearing, Times editorial page editor James Bennet stated that the editorial sought to make a point about heated political rhetoric and was not intended to blame Palin for the attack on Giffords. Palin's lawsuit was dismissed by the U.S. District Court for the Southern District of New York in August 2017. Judge Jed S. Rakoff ruled that Palin had failed to show actual malice (which, under the landmark case of New York Times Co. v. Sullivan, is the standard that a defamation plaintiff who is a public figure must show). Rakoff wrote: "What we have here is an editorial, written and rewritten rapidly in order to voice an opinion on an immediate event of importance, in which are included a few factual inaccuracies somewhat pertaining to Mrs. Palin that are very rapidly corrected. Negligence this may be; but defamation of a public figure it plainly is not." In August 2019, the U.S. Circuit Court of Appeals for the Second Circuit reinstated Palin's suit, ruling that the district court erred when it held an evidentiary hearing on the newspaper's motion to dismiss, rather than deciding the newspaper's motion to dismiss on the pleadings. In August 2020, Rakoff denied both sides' motions for summary judgment and ordered a jury trial in the libel suit. As the first libel case against the New York Times to go to trial in the U.S. in 18 years, the suit was closely watched among First Amendment scholars. The trial was initially set to begin in January 2022, but was delayed after Palin tested positive for COVID-19. On February 15, 2022, the jury of nine members reached a unanimous verdict in favor of The New York Times, finding that Palin had not proven actual malice. Jurors were aware that the previous day Rakoff said he would dismiss the case regardless of their verdict after some jurors had received push notifications on their smart phones, though jurors said it didn’t affect their deliberations. 2022 House of Representatives