New York law and Michigan law. See Curley v. AMR Corp., 153 F.3d 5, 12 (2d Cir.1998). Both New York and Michigan go beyond the constitutional minimum and require public figures to demonstrate falsity by clear and convincing evidence. See DiBella, 403 F.3d at 111 (New York); Phillips v. Ingham Cnty., 371 F.Supp.2d 918, 929-30 (W.D.Mich.2005) (Michigan). In addition, both states hold defendants “to a standard of substantial, not literal, accuracy.” Law Firm of Daniel P. Foster, P.C., 844 F.2d at 959 (New York); see also Nichols v. Moore, 477 F.3d 396, 399 (6th Cir.2007) (Michigan). Summary judgment is therefore warranted if no reasonable jury could find by clear and convincing evidence that the statements at issue are substantially false. See Anderson, 477 U.S. at 252, 106 S.Ct. 2505 (<HOLDING>). This is “a demanding standard, the most
holding that we will not review under any standard the pretrial denial of a motion for summary judgment after a full trial and final judgment on the merits holding the standard of proof in summary judgment rulings is the same as it would be at trial holding that the inquiry involved in a ruling on a motion for summary judgment  necessarily implicates the substantive evidentiary standard of proof that would apply at the trial on the merits holding that in ruling on a motion for summary judgment the trial court is limited to the grounds raised in the motion holding that a trial court can only consider admissible evidence in ruling on a motion for summary judgment