Sanders, a professor at Virginia Western Community College, sued after a newspaper wrongly reported that she improperly withheld documents from her department head. Her employment contract with the university was not renewed after the article appeared, and she was unable to obtain another position with a university. The Court affirmed a circuit court’s ruling in favor of the defendants, the publisher and the source for the article, because Sanders had not proved actual malice or reckless disregard for the truth. That standard applies when published statements relate to matters of public or general concern, because they are protected by the First Amendment and subject to qualified privilege.
