This Note explores the origens of the plaintiff's presumption of falsity and argues that, after Nazeri v. Missouri Valley College, the burden of proving falsity must be borne by the plaintiff in every case.
J. Andrew Hirth,
Laying to Rest the Ecclesiastical Presumption of Falsity: Why the Missouri Approved Instructions Should Include Falsity as an Element of Defamation,
69 Mo. L. Rev.
Available at: https://scholarship.law.missouri.edu/mlr/vol69/iss2/5