As usual, the reporter gets actual malice wrong in this story, but he gets help from an attorney:
Limbaugh May Have Grounds for Libel Suit, Legal Analysts Say
Here are the incorrect portions:
As a public figure, Wiehl said, Limbaugh would have to prove actual malice and damages — meaning he’d have to show that the media organizations knowingly and maliciously published that information without regard for the truth, and that he suffered because of it.
…
“[Limbaugh] would literally have to prove that whoever put that out did so knowingly in an attempt to hurt him,” she continued. “If I were his lawyer, I would argue actual malice. If it’s fabricated, what other reason would they make it up?”
We know from Gertz and Sullivan that actual malice is knowledge of falsity (got that right) or reckless disregard for the truth. Maliciousness has nothing to do with it, though it’s often a motivation.
We also know that making up quotes also can be evidence of actual malice.
It’s an interesting story, though, and the overall question of whether Rush could sue is a good one.