A modeling agency alleged a political ad implied that it was involved in sex trafficking. A candidate had created the agency and his opponent attacked him in the relevant ad. The AZ Supreme Court in a 4-3 decision held that the First Amendment barred the action. The Court summarized it holding this way, clearly designed to narrow its scope:
We decide today that the First Amendment precludes a defamation action based on a political advertisement directed at an opposing candidate, in which the third-party plaintiff is unnamed, the alleged defamation is not expressed but only implied, and the asserted implication is not one that would likely be drawn by a reasonable listener.