Things just got a lot tougher for those seeking to sue in New Jersey for defamation involving a matter of public concern. If the long-awaited recently enacted law seeking to curtail Strategic Lawsuits Against Public Participation ("SLAPP suits") doesn't make it difficult enough for plaintiffs, the Appellate Division recently decided Neuwirth v. State, (Aug. 2, 2023), a published decision requiring plaintiffs in all  "public concern" defamation cases, and not just those where the media is a defendant, to plead specific facts supporting an allegation of actual malice, often a difficult proposition.