William Proxmire, a U.S. senator from Wisconsin, initiated the ‘‘Golden Fleece of the Month Award'' to publicize what he believed to be wasteful government spending. The sec ond of these awards was given to the federal agencies that had for seven years funded Dr. Hutchinson's research on stress levels in animals.

The award was made in a speech Proxmire gave in the Senate; the text was also incorporated into an advance press release that was sent to 275 members of the national news media. Proxmire also referred to the research again in two subsequent newsletters sent to 100,000 constituents and during a television interview.

Hutchinson then brought this action alleging defamation resulting in personal and economic injury. Assuming that Hutchinson proved that the statements were false and defamatory, would he prevail?