Plaintiff made a sufficient showing of constitutional “malice”–i.e., knowledge of falsity or reckless with respect to truth–to survive an Anti-SLAPP motion to dismiss. In this case, plaintiff, an opposing candidate, sued Maxine Waters for falsely accusing him of having been dishonorably discharged by the Navy. Plaintiff showed Waters an official-looking document saying he was honorably discharged. Waters didn’t investigate whether it was genuine or correctly reflected his discharge status. This was enough to raise a triable issue as to reckless disregard.