Does couching factual claims in qualified language and in the passive voice suffice to render them 'true or substantially true' under the First Amendment relevant to defamation claims?

QUESTIONS PRESENTED 1. Does couching factual claims in qualified language and in the passive voice suffice to render them “true or substantially true” under the First Amendment relevant to defamation claims? 2. Does the First Amendment require that the burden of proof to establish that statements are “false” be placed on a public-figure plaintiff in a defamation suit?