American libel law has long recognized the "wire service defense"; to quote Layne v. Tribune Co. (Fla. 1933),

The mere reiteration in a daily newspaper, of an actually false, but apparently authentic news dispatch, received by a newspaper publisher from a generally recognized reliable source of daily news, such as some reputable news service agency engaged in collecting and reporting the news, cannot through publication alone be deemed per se to amount to an actionable libel by indorsement, in the absence of some showing from the nature of the article published, or otherwise, that the publisher must have acted in a negligent, reckless careless manner in reproducing it to another's injury.

The defense often arose when a newspaper publisher reprinted stories from wire services (such as the

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