Sandmann was a very different category of plaintiff.
SCOTUS gave the media pinkos an out for defaming public officials many years ago:https://en.wikipedia.org/wiki/New_York_Times_Co._v._Sullivan
NYT v. Sullivan presumes a media that is acting in good faith. Here I assume that it can be demonstrated the NYT and WaPo intentionally fabricated stories without any basis. I don’t think Sullivan should apply to such facts.
Bkmk