Plaintiff Kristen Meghan Kelly sues an online news website, The Daily Beast Company LLC, and its writer, Larrison Campbell, for alleged harm stemming from an article written by Campbell about Kelly. The other defendant is the American Industrial Hygiene Association ("AIHA")….

According to Kelly's complaint, she is a "senior industrial hygienist" with over 19 years of experience in "developing, analyzing and implementing workplace health and safety protocols." She has "presented testimony before legislative committees, appeared in documentaries, … and been engaged as a consultant throughout the country regarding workplace health and safety issues." Among other things, she opposes "mask mandates," i.e., government and private sector requirements to wear masks as a means to mitigate the spread of COVID-19. In April 2021, she appeared at a school board meeting in Hudsonville, Michigan, to express her opposition to its mask mandate. She created a video of her attendance at the meeting and then posted the video online.

Kelly's video caught the attention of Campbell, who contacted Kelly and discussed it with her. The Daily Beast later published Campbell's article about Kelly, which is titled, "Meet the Anti-Mask Michigan 'Scientist' Stoking the Fourth Wave."

Kelly sued for libel, but the court rejected the claims against The Daily Beast and Campbell. (It concluded that AIHA didn't adequately move for dismissal). Here is what strikes me as the heart of the analysis:

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