Actually, not.
Libel per se
(purr say) adj. Latin for "by itself," meaning inherently. Thus, a published writing which falsely accuses another of having a sexually transmitted disease or being a convicted felon is "libel per se," without further explanation of the meaning of the statement.
http://www.tpub.com/content/photography/14130/css/14130_175.htm It's a slamdunk since Arnold's campaign accused her of being a criminal.