Does the First Amendment or Gertz v. Robert Welch, Inc. impose limitations on defamation claims by private, non-public figures involved in private matters?

QUESTIONS PRESENTED. 1. Does either the First Amendment or this Court’s holding in Gertz v. Robert Welch, Inc., 418 U.S. 323, 341 (1974) impose any limitations upon common law defamation claims in the context of a private, non-public figure involved in a matter of “private concern”? 2. While the court below reaffirmed the validity of the common law Doctrine of Republication— which permits defamation claims against “republishers” of factually-false representations— in Yohe v. Nugent, 321 F.3d 35, 48 (1st Cir. 2003), the First Circuit rejected this Doctrine, declining to impose liability where the republisher had “accurately” reiterated the factually-false representations made by a third party; which of these contradictory and _ antithetical precedents is correct? 3. Is Mass. Gen. Laws ch. 41 § 98F, as applied, . violative of the Due Process Clause of the United States Constitution, viz. Amend. XIV, § 1, or alternatively, does it constitute a legislative bill of attainder, in violation of Art. I, § 10, Cl. 1?