The National Enquirer (defendant) published a four-sentence article in its gossip column that claimed that Carol Burnett (plaintiff) got into a loud argument with Henry Kissinger and acted erratically at a restaurant. Burnett’s attorney requested in writing that the National Enquirer print a correction or retraction, which the National Enquirer did print. Burnett nonetheless filed suit for libel. The jury awarded Burnett $300,000 in compensatory damages and $1.3 million in punitive damages. The trial court reduced the damages award to $50,000 in compensatory and $750,000 in punitive damages. The National Enquirer appealed.