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by sio8ohPi 2276 days ago
This simply isn't true. See for instance Batra v Wolf et al, among many other examples:

https://www.loeb.com/en/insights/publications/2008/04/batra-...

> Plaintiff Ravi Batra, a bald, Indian-American lawyer involved in a judicial corruption scandal, filed a libel-in-fiction claim against the writers, producers and broadcasters of the television show Law & Order, claiming that an episode about a judicial bribery scandal that included a character who was a bald, Indian-American lawyer named Ravi Patel was defamatory. The court reached this holding after noting that no libel-in-fiction law suit in New York state court had survived a motion to dismiss in almost 25 years, and then denied defendants’ motion to dismiss.

Actual malice is additionally only necessary if the victim is a public figure.