He's referring to the standard for defamation set out in
New York Times v. Sullivan. This case sets out the nearly impenetrable barrier between free speech and defamation when the subject of the speech is a public figure, as most politicians and celebrities are.
He doesn't get it, though.
"Malice" is the definitive word. It doesn't mean emotional malice, which this horrid mutant obviously has. However, what it really means, according to the Supreme Court, is that "the statement was made with knowledge of its falsity or with reckless disregard of whether it was true or false."
The psychotic midget with a paralyzed face clearly falls into one or two of these categories.
