I think that they should have to prove actual harm because Milagro is still a public figure. She may not have the same protections as a journalist but if a judge is reviewing the substance of someone’s speech then it should be examined under the strict scrutiny standard. New York Times v. Sullivan is the controlling case. In that case, L.B. Sullivan, a city commissioner who supervised the police, sued the newspaper for libel, claiming the ad damaged his reputation. The Supreme Court ruled in favor of the New York Times, establishing the "actual malice" standard for public officials and public figures. This prevents public officials from winning libel cases based on minor inaccuracies in news coverage or criticism of official conduct.  Celebrities and other public officials have always had tough luck regarding freedom of speech cases because of this specific case.