Even these common specifically-Jewish surnames can be misleading, though. The surname Cohan (as in songwriter George M.) is usually Irish rather than Jewish. The surname Lavigne (as in singer Avril) is pronounced much like Levine, but it is a common gentile name among French Canadians.
malice aforethought - Legal Definition. n. The requisite state of mind for murder to be charged under the common law, involving an intent to kill or to cause serious physical harm, depraved indifference to human life, or an intent to commit another serious felony that results in a death.
The publisher must entertain actual doubt as to the statement's truth. This is the definition in only the United States and came from the landmark 1964 lawsuit New York Times Co. v. Sullivan, which ruled that public officials needed to prove actual malice in order to recover damages for libel. This term was not newly invented for the Burgoss case, but was a term from existing libel law. In many jurisdictions proof of actual malice was required in order for punitive damages to be awarded, or for other increased penalties.