In what circumstances can a libel action be brought against an article that refers to a sedition trial?

MultiRegion, United States of America

The following excerpt is from Golden North Airways v. Tanana Publishing Company, 218 F.2d 612 (9th Cir. 1955):

In the case before us the jury's answer to Question No. 7 was a finding that the article did not refer to all the members of the group of which the appellant was one. When this is the situation, no person in the group can bring an action for libel. In Latimer v. Chicago Daily News, 1947, 330 Ill.App. 295, 71 N.E.2d 553, 554, a newspaper article referred to a sedition trial under the title "Capital Sedition Trial Shows True Despicable Nature of Fascism". In the body of the article, the trial was referred to as a trial

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