The article begins:
A Manhattan Supreme Court justice has dismissed a $100 million libel lawsuit against the author and publisher of "Primary Colors," the fictionalized insider account of former President Bill Clinton's 1992 presidential campaign.
In dismissing the action by Daria Carter-Clark, Justice Richard F. Braun found that, as a work of fiction, the book should not be held to the same investigatory standards as non-fiction work. For that reason, he held in Carter-Clark v. Random House Inc., 122266/96, that Carter-Clark had not shown that her reputation was damaged by the depiction of one of the book's characters that she said was based on her.
And then it ends:
"No one disputes that this book was inspired by real life as most works of fiction are, but that doesn't change the fact that at the end of the day this is a work of fiction," said Elizabeth A. McNamara, a partner at Davis Wright Tremaine who represented the defendants along with Gregory A. Welch.
McNamara said she was particularly pleased that the court recognized "publishers don't have an obligation to investigate fictional works prior to publication," in what she said was an issue of first impression.
Sounds right to me. Details here.