Mrs. o'leary's cow was famously accused of knocking over a lantern and causing the great chicago fire of 1871. michael ahern, a reporter, admitted to making up the story. which would need to be true in order for his story to be constitutionally protected free speech?

if at the time, ahern had no reason to believe the cow had in fact started the fire

ahern would have need to have worked for the press

if mrs. o'leary was not harmed by ahern's report

ahern would have to have verbally stated that the cow had started the fire