In St. Amant v. Thompson, 390 U.S. 727, 731, 20 L. Ed. 2d 262, 88 S. Ct. 1323 (1968), the Court held that the circumstantial evidence of objective unreasonableness proved only that -- unreasonableness, not subjective doubt. 390 U.S. at 731. The Court reached this conclusion despite evidence that the defendant had no personal knowledge of the truth or falsity of his comments and had completely failed to conduct any investigation of his allegations before publishing them. Id. at 730-33.