U.S. Representative Devin Nunes of California sued journalist Ryan Lizza and Hearst Magazine Media over an article Lizza wrote about the alleged employment of noncitizens without work authorization on a farm operated by Nunes's relatives. The Eighth Circuit upheld the Rule 12 dismissal of Nunes's claims about the news article itself. But the court reversed and remanded the remainder of the suit, concluding that the complaint raised a plausible inference of actual malice because, after the lawsuit was filed, Lizza posted a tweet with a link to the article. That is, the complaint sufficiently alleged that the article had been republished with reckless disregard of whether the article was false or not—because Lizza knew when he posted the link that Nunes was denying the truth of the article's contents.