1276 REVIEW GRANTED The privilege of neutral reportage has not been adopted in California and, in any event, does not apply to reports of false accusations about persons who are not public figures; standing near a presidential candidate shortly before he was assassinated does not make a person a public figure; a publisher's failure to investigate glaringly improbable statements before reporting on them is circumstantial evidence that it entertained doubts about them and deliberately avoided ascertaining the truth, which satisfies the requirement of "actual malice" and justifies an award of punitive damages.CitationKHAWAR v GLOBE (RFK Assassination) 46 CA4 1 [See: Stolz v KSFM 30 CA4 195, T/AT 12/94; Denney v Lawrence 22 CA4 927, T/AT 3/94; Gilman v McClatchy 111 C 606; Gertz v Robert Welch 418 US 323; St Amant v Thompson 390 US 727]
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