Partington v. Bugliosi (9th Cir. 1995) 56 F.3d 1147, provides a well-reasoned analysis of when criticism of an attorney's conduct is actionable. There, the court discussed comments made in attorney Vincent Bugliosi's book about another attorney's unsuccessful representation of a defendant in a murder case; Bugliosi had obtained an acquittal for the codefendant in a separate trial. Since Bugliosi was a participant and was providing his personal account of the litigation, "a reader would be likely to recognize that the critiques of the judges, witnesses, and other participants in the litigation-- and particularly of the other counsel--generally represent the highly subjective opinions of the author rather than assertions of verifiable, objective facts." (Id. at p. 1154.) Although Bugliosi clearly implied that the second attorney had inadequately represented his client (id. at p. 1157), "critiques of a lawyer's performance in a particular case generally cannot be proved true or false and, consequently, cannot ordinarily serve as the basis of a defamation claim. ... ... ... Courts should be reluctant to hold comments concerning the professional abilities of an individual actionable." (Id. at pp. 1158-1159.)