In Harte-Hanks Comms., Inc. v. Connaughton, 491 U.S. 657 (1989), Connaughton, an unsuccessful candidate for municipal judge, sued Harte-Hanks, a newspaper publisher, for libel. After one of the incumbent's court officials was arrested on bribery charges and while a grand jury investigation of those charges was in progress, the newspaper published a front-page story quoting witness Alice Thompson stating that Connaughton "had used 'dirty tricks' and offered her and her sister jobs and a trip to Florida 'in appreciation' for their help in the investigation." Id. The United States Supreme Court concluded that the newspaper acted with actual malice in printing defamatory and false statements based on evidence including: (1) by the day the story appeared, six witnesses--including Connaughton--"had categorically denied Thompsons' allegations"; (2) the newspaper chose not to interview "the one witness who was most likely to confirm Thompson's account"; (3) the newspaper decided not to listen to tapes of an interview that "could easily have . . . verified or disproved" much of the published statements, even though Connaughton made the tapes available; and (4) "the hesitant, inaudible, and sometimes unresponsive and improbable tones of Thompson's answers to various leading questions in a taped interview raised obvious doubts about her veracity." Id. at 690. The court concluded that, accepting "the jury's determination that Harte-Hanks's explanations for these omissions were not credible, it is likely that the newspaper's inaction was a product of a deliberate decision not to acquire knowledge of facts that might confirm the probable falsity of Thompson's charges." Id. at 692. The court noted that while a failure to investigate "will not alone support a finding of actual malice, the purposeful avoidance of the truth is in a different category." Id.