Ms. Muhlhahn claims that Mr. Goldman painted her as reckless, but New York has filed a motion to dismiss on the grounds that writing about somebody's divergence from medical opinon can't be defamation.

“I’m not that comfortable with VBACs at home, but I know most can have them fine,” Ms. Muhlhahn told Mr. Goldman at one point in the piece. "Most VBAC mommies know they have less of a chance of giving birth vaginally in a hospital.”

The Observer reported earlier this summer on the increasing scarcity of libel cases — not to mention successful ones — against media organizations these days. We're not lawyers, but New York seems very safe here. Ms. Muhlhahn is being sued herself by two of her clients, who had a stillborn baby after three days of labor.

Earlier: The End of Libel?