During Roy Moore’s 2017 Senate campaign, Senate Majority PAC repeatedly broadcast an ad combining reports about his alleged conduct at a shopping mall with a separate report about a 14-year-old Santa’s helper. A jury treated the combination as a defamatory implication and awarded Moore $8.2 million. The Eleventh Circuit held that Moore lacked evidence that SMP intended or recklessly disregarded the alleged implication—the actual-malice requirement for a political defamation-by-implication claim—so it reversed and remanded with instructions to enter judgment for SMP.