[mrunkel]

Because there was no intent to harm, which is a component of libel.

[leephillips]

No, it is not. If there is any state where this is necessary to sustain an action for libel, please link to the relevant statute.

Note: I am not a lawyer, but I was sued for libel by radio health weirdo Gary Null and, in a separate action, by his sidekick. They lost.