In Beilenson v. Superior Court (1996) 44 Cal. App. 4th 944, a campaign mailer stated that a congressional candidate's maintenance of a private law practice while working for the state was "unethical." (Id. at p. 947.) Although the defeated candidate established to the court's satisfaction that "there was nothing illegal or unethical in keeping his law practice while in the employ of the state," his opponents' failure to contact the Fair Political Practices Commission to discover that fact did not justify a finding that they acted with actual malice. (Id. at p. 952.)