In Reader's Digest Assn. v. Superior Court (1984) 37 Cal. 3d 244, the Supreme Court issued a writ of mandate directing the trial court to grant the defendants' motion for summary judgment in a defamation action. Noting that public figure plaintiffs need to prove actual malice (now referred to as "constitutional malice") by clear and convincing evidence at trial, the Supreme Court held that, when evaluating the evidence concerning this element of the tort on a defendant's motion for summary judgment, the evidence and all inferences that reasonably can be drawn from it must meet the higher standard. (Id. at p. 252.) Summary judgment should be granted "unless it appears that actual malice may be proved at trial by clear and convincing evidence . . . ." (Ibid.)