Judge refuses to grant Sarah Palin a new trial in her libel lawsuit against The New York Times

It was the second jury to reach that conclusion after the 2nd U.S. Circuit Court of Appeals in Manhattan ordered a new trial after Rakoff in February 2022 said while the jury in the first trial was deliberating that he planned to dismiss the lawsuit because Palin had failed to show that the newspaper had acted out of malice.

Regarding the request to recuse himself, the judge said the trial transcript shows he frequently ruled in Palin's favor during the trials.

Danielle Rhoades Ha, a spokesperson for the newspaper, said in an email that the Times was pleased with the decision.

"The jury reached the right verdict in rejecting Palin’s libel claim, and today’s decision reaffirms the jury’s decision,” she said.

Lawyers did not immediately respond to requests for comment.

Palin sued the Times for unspecified damages in 2017, a decade after she was chosen by then-U.S. Sen. John McCain of Arizona as the Republican vice presidential nominee. McCain died in 2018.

The lawsuit said Palin was libeled by an editorial about gun control published after U.S. Rep. Steve Scalise, a Louisiana Republican, was wounded in 2017 when a man with a history of anti-GOP activity opened fire on a congressional baseball team practice in Washington.

In the editorial, the Times wrote that before the 2011 mass shooting in Arizona that severely wounded former U.S. Rep. Gabby Giffords and killed six others, Palin’s political action committee contributed to an atmosphere of violence by circulating a map of electoral districts that depicted Giffords and 19 other Democrats under stylized crosshairs.

The Times corrected the article less than 14 hours after it was published, saying it had “incorrectly stated that a link existed between political rhetoric and the 2011 shooting” and that it had “incorrectly described” the map.

During this year's trial, former Times editorial page editor James Bennet tearfully apologized to Palin, saying he was tormented by the error and worked urgently to correct it after readers complained to the newspaper.

Palin, who earned a journalism degree in college, testified that death threats against her increased and her spirits fell after the editorial was published.