"'actual malice'–that is, with knowledge that it was false or with reckless disregard of whether it was false or not."
So, in addition to "reckless disregard," if the speaker or writer KNEW the defamatory statement against a public figure was false (and not parody), they are liable.
Even though the libel against Trump is huge, the damages there are a small fraction of the total damage this hoax has done. Look at the ruined institutional reputation, public trust is PROPERLY withheld, unnecessary foreign policy headwind.
Estimated half a billion dollars to lawyers from people targeted by Mueller. Innocent people who were not personally libeled, but were targeted by the DOJ (via Mueller) because they had some association with Trump.
US intelligence and criminal justice systems were turned against the US public. "Russian collusion" is a fart in the wind compared with the damage done by the US government. The "fine people" in the FBI, CIA, DOJ, State Department (and the press), and some in the Courts did "some really bad things."