In Sanborn v. Chronicle Publishing Co. (1976) 18 Cal.3d 406, the defendant stated to the press he had been conned by the plaintiff into releasing impounded funds without legal authority to do so. The court held the evidence supported the jury's implied finding of malice, i.e., that he wanted to transfer the blame for the loss of the funds to plaintiff, thereby exculpating himself in the eyes of the press and general public.