[othermaciej]

I looked up th case you cited, a copy of the opinion of the court may be found here: http://law.justia.com/cases/california/caapp4th/30/943.html

As far as I can tell, it doesn't say what you claim it does. There is no mention of burden of proof or prima facile case at all. It merely states that truth is an absolute defense, but that is only the case because it precludes the plaintiff meeting their burden of proof to show falsity.

Since you mention a distinction between private and public indviduals, I suspect you are confusing the issue of burden of proof with the "actual malice" standard, which must be met to establish defamation of a public figure but not a private figure. This is established by Supreme Court precedents Arthur v Sullivan and Getz v Robert Welch Inc, both of which are cited in the law review article I mentioned and both of which maintain falsity as a required element of the offense. (In case you were wondering, Supreme Court precedent trumps Circuit Court precedent in the US, so even if the case said what you claimed it would not be informative about the state of the law of defamation.)