Jerry Katz, a politician, stated that he would not raise taxes if elected. The local newspaper supported Katz, who won the election. At his first board meeting, Katz moved to raise taxes.
That prompted an editorial that began, "Jerry Katz is a liar. He has lied to us in the past, and he will lie to us in the future." Katz sued the newspaper. What would that action be, and what would be the likely result? [Costello v. Capital Cities Communications, 505 N.E.2d 701, App. Ct., Ill. (1987)]