POPOVICH, Chief Justice.
On November 15, 1981, the Duluth News-Tribune published three articles concerning battered women that were critical of the job performance of the Carlton County Attorney, Donald Diesen, in prosecuting domestic abuse. Diesen sued the News-Tribune, its executive editor, Thomas Daly, and the reporter who wrote the articles, John Hessburg, for libel. The jury found by special verdict the articles’ implication was substantially false, appellants published the articles with actual malice, and awarded Diesen $285,000 in compensatory and $500,000 in punitive damages. The trial court granted appellants’ motion for judgment notwithstanding the verdict (JNOV), holding a libel action by a public official cannot be based on a false implication arising from true facts, and any implication from the articles was constitutionally protected opinion. A Minnesota Court of Appeals panel reversed and reinstated the jury’s verdict. Diesen v. Hessburg, 437 N.W.2d 705, 712 (Minn.App.1989). We reverse.
I.
In the spring of 1981, John Hessburg, a reporter for the Duluth News-Tribune, was assigned to investigate a complaint received by the newspaper that Carlton [448]*448County was lenient in prosecuting men who battered women. Hessburg met with victims of domestic abuse and advocates for battered women, examined Initial Complaint Reports (ICRs) in Carlton County, and developed flow charts detailing the dispositions of the 44 ICRs that involved domestic assaults. Hessburg interviewed Donald Diesen, who was then Carlton County Attorney, as well as other law enforcement and judicial officials, and several local attorneys. From the outset, Hess-burg referred to the investigation as “the Diesen probe.” Diesen and the Duluth News-Tribune exchanged a series of correspondence regarding the investigation. Diesen informed the newspaper that Hess-burg was making false accusations about him, asked to meet with someone from the paper other than Hessburg, and requested a transcript of his interview with Hess-burg. These requests were denied in accordance with the Duluth News-Tribune’s policy .and consistent with standard journalism practice.
Two Duluth News-Tribune city editors verified the file dispositions and information used by Hessburg. One editor also reviewed tapes of Hessburg’s interviews. Although this review indicated Hessburg asked leading questions and had become “deeply, emotionally involved in” the investigation, the editor could find no inconsistencies between the interviews and what Hessburg had written. The News-Tribune decided not to publish articles concerning two battered women because they could not be independently confirmed. The News-Tribune’s attorney reviewed the articles prior to publication and opined the material was not libelous because “[t]he material appears to be well documented and well within the area of permitted criticism of the court system and those who run it.” The three articles that appeared in the Duluth News-Tribune on Sunday, November 15, 1981 were: Is justice denied battered women in Carlton County?; Justice denied? The case of Kathy Berg-lund; and County Attorney Donald Dies-en: Critics say he’s not tough on domestic abuse. Diesen’s demand for a retraction was denied by the News-Tribune. Although Diesen was defeated in the 1982 election for Carlton County Attorney, the articles were not used in the campaign.
Diesen brought a libel action against Hessburg, Daly, and the Duluth News-Tribune (collectively “Newspaper”), alleging the articles defamed him. Appellants sought summary judgment as to those portions of the articles admitted by Diesen in his deposition to be favorable, balanced, true or opinion. The trial court denied the motion and held Diesen could proceed under the implication theory. Appellants’ second summary judgment motion, which contended the absence of any evidence tending to show actual malice, was denied. A third summary judgment motion, arguing the trial court applied an incorrect summary judgment standard regarding actual malice, was also denied. Appellants then brought a motion in limine to strike those portions of the articles admitted by Diesen not to be false or libelous, which was denied.
Several of the victims, battered women’s advocates and attorneys testified at trial the articles quoted them or reflected their stories accurately. Supporters of Diesen, such as Sheriff Twomey and Sergeant Randelin, also testified that quotations attributed to them in the articles were fair and accurate. At trial Diesen answered, for example, “true,” “opinion,” “O.K.” or “fair,” in response to an extensive, paragraph by paragraph cross-examination of the published articles. While the editors and publisher acknowledged the articles impliedly charged Diesen with malfeasance or misfeasance, they also testified to their belief the articles were true. The only expert witness called, Journalism Professor Ralph Holsinger of Indiana University, testified the newspaper did not violate any journalism standards in reporting, editing or publishing the articles.
After Diesen rested, appellants moved for a directed verdict, which the trial court denied. The court also denied appellants’ motion to prohibit Diesen’s punitive damages claim. At the close of all the evidence, appellants again moved for a directed verdict, to which the trial court respond[449]*449ed, “The Court would be inclined to either grant a judgment notwithstanding the verdict in favor of the defendant, or * * * may upon receipt of an unfavorable verdict to the defendant, grant the [directed verdict] motion that has now been requested by the defendant.”
The trial court held as a matter of law that all statements in the articles were true and so instructed the jury. By special verdict, the jury found:
[T]he implication of the articles published by Defendants [was] substantially false
Plaintiff [did not] demonstrate by clear and convincing evidence that the Defendants knew that the implication of the articles was substantially false * * *
Plaintiff prove[d] by clear and convincing evidence that the Defendants published the articles with reckless disregard as to the truth or falsity of the implication of said articles.
The jury then awarded Diesen $285,000 in compensatory damages and $500,000 in punitive damages. Appellants moved the trial court for JNOV or a new trial. The trial court granted JNOV, ruling that the alleged implication was too vague to be actionable; “[t]here can be no libel by innuendo if the challenged communication is true and concerns public officers and public affairs even though a false implication may reasonably be drawn”; and “the implication arising from the articles” was constitutionally protected opinion. Diesen appealed.
A Minnesota Court of Appeals panel reversed and reinstated the jury’s verdict, holding known facts were omitted from the articles that created a false implication; the record supported the finding of actual malice; and the statements implying Dies-en’s malfeasance or misfeasance were not constitutionally protected opinion. Diesen v. Hessburg, 437 N.W.2d 705, 710-12 (Minn.App.1989). We granted further review to Hessburg, Daly and the Duluth News-Tribune and now reverse.
II.
Granting a JNOV is a question of law subject to de novo review. See Edgewater Motels, Inc. v. Gatzke, 277 N.W.2d 11, 14 (Minn.1979). Essentially we are asked here to recognize a legal theory: whether a public official plaintiff may bring a libel by implication action against a -media defendant, which is a question of law. See W. Prosser & W. Keeton, The Law of Torts § 3, at 18-19 (5th ed. 1984) (hereinafter “Law of Torts ”). Thus, we conduct an independent review of the record before us. Appellants Hessburg, Daly and the Duluth News-Tribune urge us to reject the libel by implication theory because it allows a plaintiff to avoid prov- . ing the falsity of alleged defamatory statements. Generally, a plaintiff must prove publication of a false and defamatory statement to prevail in a libel action, with truth being an affirmative defense to such a claim. Id. § 116, at 839. Here, however, the trial court found the statements in the articles to be true as a matter of law. Respondent Diesen argues the articles are actionable because their implication, Dies-en’s misfeasance or malfeasance regarding prosecution of domestic abuse, was false.
The jury found “the implication of the articles published by Defendants [was] substantially false.” The court of appeals panel concurred due to the following omissions in the Berglund article:
The article correctly states that Diesen plea bargained the felony assault charge to a misdemeanor. However, the article failed to mention that Kathy Berglund had told the assailant’s probation officer that she believed chemical dependency treatment was more appropriate for Melvin Defoe, the assailant. The article also neglected to mention that Diesen had requested jail time for Defoe. The article also failed to mention that Berglund admitted that she was unwilling to go through any court process at that point in time. * * * By the omission of these facts, the reader is left with the view that even though Berglund was severely assaulted by this man, Diesen did not believe it merited felony prosecution
[450]*450Diesen, 437 N.W.2d at 708. Berglund, however, testified at trial she “wanted him prosecuted” rather than just getting treatment for DeFoe. She also testified she “never dropped the action,” but she could not get a response from Diesen after numerous attempts. In addition to those noted by the court of appeals panel, Diesen cites other minor “omissions and distortions,” involving, for instance, the Chip Martin story. These omissions, considering the totality of the articles, would have had no material effect in changing the thrust and tenor of the articles. Moreover, even if facts were omitted from the published articles, arguably such organizing, and editing of the articles were within the Newspaper’s discretion. See, e.g., Strada v. Connecticut Newspapers, Inc., 193 Conn. 313, 326, 477 A.2d 1005, 1012 (1984).
While Prosser recognizes “if the defendant juxtaposes a series of facts so as to imply a defamatory connection between them, or creates a defamatory implication by omitting facts, he may be held responsible for the defamatory implication, unless it qualifies as an opinion, even though the particular facts are correct,” Law of Torts § 116 (Supp.1988) (footnotes omitted), this reference is to common law libel in the absence of the constitutional concern for fair comment on public officials. The United States Supreme Court has established an important distinction between private and public official plaintiffs for defamation purposes. Greater constitutional protection is afforded speech about public officials’ public conduct and other matters of public concern than that of a strictly private nature because of our “profound national commitment to the principle that debate on public issues should be uninhibited, robust, and wide-open, [although] it may well include vehement, caustic, and sometimes unpleasantly sharp attacks on government and public officials.” New York Times Co. v. Sullivan, 376 U.S. 254, 270, 84 S.Ct. 710, 720, 11 L.Ed.2d 686 (1964); see also Rose v. Koch, 278 Minn. 235, 254, 154 N.W.2d 409, 423 (1967).
The subjects of the three articles, the treatment of battered women and the county attorney’s job performance, are matters of public concern. Diesen, as county attorney, was a public official and as such, “runs the risk' of closer public scrutiny than might otherwise be the case.” Gertz v. Robert Welch, Inc., 418 U.S. 323, 344, 94 S.Ct. 2997, 3009, 41 L.Ed.2d 789 (1974). This scrutiny is considered a necessary and positive element of our democracy and, as a result, a public official may suffer injury to his or her professional reputation without recovery under defamation law because of the paramount free speech and free press rights at stake. Public officials also are given less protection because they “generally have some access to a public medium for answering disparaging falsehood[s], whereas private individuals do not.” Law of Torts § 113, at 805.
As a public official, Diesen had a natural forum to explain the functioning of his office and to counter the thrust of the articles. Although Diesen demanded a retraction from the Newspaper, which was denied, he did not avail himself of other avenues, such as holding a news conference. Se did, however, submit comments to other local papers, the Cloquet Pine Knot and the Moose Lake Star and Gazette, which published editorials favorable to him. It is interesting to note the average circulation in Carlton County for the Sunday Duluth News-Tribune in 1981 was 6,829, while the figures for the Cloquet Pine Knot and the Moose Lake Star and Gazette were 5,650 and 3,400 respectively. Also, although Diesen was defeated in the next election for county attorney, the subject articles were not part of his or his opponent’s campaign. Indeed, it was not a very close election since Diesen’s opponent won by an approximate 3,000 vote margin. Moreover, evidence at trial indicated opinions generally of Diesen did not change as a result of the articles.
To further safeguard speech, the Supreme Court has held expressions of opinion are not actionable statements for defamation purposes and are protected by the first amendment. Gertz, 418 U.S. at 339-40, 94 S.Ct. at 3006-07.
Under the First Amendment there is no such thing as a false idea. However [451]*451pernicious an opinion may seem, we depend for its correction not on the conscience of judges and juries but on the competition of other ideas. But there is no constitutional value in false statements of fact.
Id. (footnote omitted). Because the Supreme Court has provided only limited guidance on this issue, “the lower federal courts and state courts have, not surprisingly, fashioned various approaches in attempting to articulate the Gertz — mandated distinction between fact and opinion.” Oilman v. Evans, 750 F.2d 970, 977 (D.C.Cir.1984), cert. denied, 471 U.S. 1127, 105 S.Ct. 2662, 86 L.Ed.2d 278 (1985); see also Janklow v. Newsweek, Inc., 788 F.2d 1300, 1302 (8th Cir.), cert. denied, 479 U.S. 883, 107 S.Ct. 272, 93 L.Ed.2d 249 (1986); Information Control Corp. v. Genesis One Computer Corp., 611 F.2d 781, 783-84 (9th Cir.1980).
The challenged statements’ specificity and verifiability, as well as their literary and public context, are factors used by courts in distinguishing between fact and opinion. E.g., Janklow, 788 F.2d at 1302-03; Oilman, 750 F.2d at 979. The allegedly false implication here arguably was unspecific and unverifiable. The articles, however, contained quotations and opinions both favorable and unfavorable to Diesen, as well as cautionary language, and two of the three articles were printed in the editorial section of the News-Tribune. Under this analysis, then, the challenged speech was protected opinion. Although not specifically espoused by the Supreme Court in Harte-Hanks Communications, Inc. v. Connaughton, — U.S. -, 109 S.Ct. 2678, 105 L.Ed.2d 562 (1989), similar factors have been used by the Court in its defamation analysis. E.g., Old Dominion Branch No. 496, Nat’l Ass’n of Letter Carriers v. Austin, 418 U.S. 264, 284-85, 94 S.Ct. 2770, 2781, 41 L.Ed.2d 745 (1974) (a union’s “scab” description held protected opinion based on linguistic context and social setting); Greenbelt Cooperative Publishing Ass’n, Inc. v. Bresler, 398 U.S. 6, 14, 90 S.Ct. 1537, 1542, 26 L.Ed.2d 6 (1970) (“blackmail” characterization in light of article’s full context was deemed merely “rhetorical hyperbole”).1
In a recent decision, the Eighth Circuit held, “We do not recognize defamation by implication,” in affirming summary judgment against a public figure. Price v. Viking Penguin, Inc., 881 F.2d 1426, 1432 (8th Cir.1989) (citing Janklow, 788 F.2d at 1304), cert. denied, — U.S. -, 110 S.Ct. 757, 107 L.Ed.2d 774 (1990); accord Fudge v. Penthouse Int’l, Ltd., 840 F.2d 1012, 1016-17 (1st Cir.), cert. denied, — U.S. -, 109 S.Ct. 65, 102 L.Ed.2d 42 (1988). An FBI agent in Price sued a media defendant for allegedly defamatory statements and implications contained in a book, but was not allowed to recover largely because the challenged assertions of improper motive were protected opinion under the Jank-low totality of the circumstances analysis. 881 F.2d at 1432. Other jurisdictions have also specifically declined to allow a public official to prove falsity by implication where the challenged statements are true. See, e.g., Cibenko v. Worth Publishers, Inc., 510 F.Supp. 761, 765 (D.N.J.1981); Pietrafeso v. D.P.I., Inc., 757 P.2d 1113, 1115-16 (Colo.Ct.App.1988); Strada, 193 Conn. at 326, 477 A.2d at 1012; Schaefer v. Lynch, 406 So.2d 185, 188 (La.1981). We concur, believing the subject articles fall within the protected purview as described by the Janklow court:
[Sjpeech about government and its officers, about how well or badly they carry out their duties, lies at the very heart of [452]*452the First Amendment * * *. It is vital to our form of government that press and citizens alike be free to discuss and, if they see fit, impugn the motives of public officials.
788 F.2d at 1304-05 (citations and footnote omitted).
We have held on numerous occasions that truth is a complete defense to defamation and “true statements, however disparaging, are not actionable.” Stuempges v. Parke, Davis & Co., 297 N.W.2d 252, 255 (Minn.1980) (employer’s statements about work record of former employee deemed false and defamatory); see also Lewis v. Equitable Life Assurance Soc’y, 389 N.W.2d 876, 888 (Minn.1986). In Lewis, we noted that “[e]ven though an untrue defamatory statement has been published, the originator of the statement will not be held liable if the statement is published under circumstances that make it conditionally privileged and if [that] privilege is not abused.” Id. at 889. We reiterate that like protected opinion and “fair comment” on public officials, “[t]he doctrine of privileged communication rests upon public policy considerations [and] results from the court’s determination that statements made in particular contexts or on certain occasions should be encouraged despite the risk that the statements might be defamatory.” Id. Thus, while first amendment and other policy considerations underlie this restraint, we note our decision here is rooted in state defamation law.
A trial court must view the evidence in the light most favorable to the jury verdict, Lamb v. Jordan, 333 N.W.2d 852, 855 (Minn.1983), and should not grant JNOV unless “the evidence is practically conclusive against the verdict and reasonable minds can reach only one conclusion.” Nadeau v. County of Ramsey, 277 N.W.2d 520, 522 (Minn.1979). Granting JNOV is also proper when the jury’s findings are “contrary to the law applicable in the case.” Dean v. Weisbrod, 300 Minn. 37, 41-42, 217 N.W.2d 739, 742-43 (1974). A trial court has the power to grant JNOV and to set aside a special verdict when “it appears that the evidence cannot sustain the verdict.” 3 D. McFarland & W. Kep-pel, Minnesota Civil Practice § 2123, at 522-23 (1979) (footnote omitted). When a special verdict is used, as here, the jury is required only to find the facts and “it remains for the court to apply the law to the facts and render a judgment.” Id. at 522. In Nadeau, we held the trial court did not err in granting JNOV after the jury in a special verdict found the defendant liable for slander because there was no evidence of “any false and defamatory remarks about plaintiff.” 277 N.W.2d at 523. We hold granting JNOV here was proper. Because the printed articles admittedly contained only true statements or opinion, and any implication therefrom was constitutionally protected criticism of a public official, there was no defamatory “speech” as a matter of law.
III.
Once a public official plaintiff establishes the existence of defamatory statements, the official, to prevail, must then also prove the media defendant acted with actual malice in publishing the statements. New York Times, 376 U.S. at 279-80, 84 S.Ct. at 725-26. While we hold an allegedly false implication arising out of true statements is generally not actionable in defamation by a public official, we nevertheless address whether the record establishes actual malice with convincing clarity because the parties argued and briefed the issue, and due to the independent review standard set forth by the United States Supreme Court. Bose Corp. v. Consumers Union of U.S., Inc., 466 U.S. 485, 514 & n. 31, 104 S.Ct. 1949, 1967 & n. 31, 80 L.Ed.2d 502 reh’g denied, 467 U.S. 1267, 104 S.Ct. 3561, 82 L.Ed.2d 863 (1984); see also Harte-Hanks, — U.S. at -, 109 S.Ct. at 2695, 105 L.Ed.2d 562 (affirming Bose clear and convincing evidence standard); Jadwin v. Minneapolis Star & Tribune Co., 367 N.W.2d 476, 492 n. 21 (Minn.1985) (adopting Bose standard).
Actual malice for defamation purposes has been interpreted to mean the defendant acted with a reckless disregard for the truth or had a high degree of [453]*453knowledge of the statements’ probable falsity. Herbert v. Lando, 441 U.S. 153, 156—57, 99 S.Ct. 1635, 1638-39, 60 L.Ed.2d 115 (1979). Diesen contends Hessburg acted with actual malice, for example, by fabricating information in establishing a basis to accuse Diesen, badgering interviewees and asking leading questions of them. While Hessburg may have intended to discredit Diesen, “motives of diminishing plaintiffs credibility” do not establish actual malice when there was no evidence the media had actual knowledge of falsity. Fitzgerald v. Minnesota Chiropractic Ass’n, 294 N.W.2d 269, 271 (Minn.1980); see also Westmoreland v. CBS Inc., 596 F.Supp. 1170, 1174 (S.D.N.Y.1984) (“a determined effort to confirm a previously formed suspicion * * * does not establish malice”). Further, any ill will Hessburg may have had toward Diesen is irrelevant to the actual malice inquiry. E.g., Harte-Hanks, — U.S. at -, 109 S.Ct. at 2685 n. 7 (“ ‘actual malice’ is unfortunately confusing in that it has nothing to do with bad motive or ill will”).
Even if Hessburg used abrasive or antagonistic investigatory techniques, such factors do not establish actual malice. See e.g., id. at-, 109 S.Ct. at 2684 (“extreme departure from professional standards” insufficient); Reader’s Digest Ass’n, Inc. v. Superior Court, 37 Cal.3d 244, 258, 690 P.2d 610, 619, 208 Cal.Rptr. 137, 146 (1984) (failure to conduct thorough, objective investigation insufficient (citing St. Amant v. Thompson, 390 U.S. 727, 733, 88 S.Ct. 1323, 1326, 20 L.Ed.2d 262 (1968))), cert. denied, 478 U.S. 1009, 106 S.Ct. 3307, 92 L.Ed.2d 720 (1986). Further, “[a]n adversarial stance is certainly not indicative of actual malice * * * where, as here, the reporter conducted a detailed investigation and wrote a story that is substantially true.” Tavoulareas v. Piro, 817 F.2d 762, 795-96 (D.C.Cir.) (citing Westmoreland, 596 F.Supp. at 1174), cert. denied, 484 U.S. 870, 108 S.Ct. 200, 98 L.Ed.2d 151 (1987). It is not disputed Hessburg conducted a detailed investigation and the articles’ sources testified that statements attributed to them were true.
While Diesen contends the Newspaper acted maliciously by “us[ing] material out of context[,] arranging] facts within the article[s,] * * * highlighting] the negative opinions and downplaying] the favorable opinions,” arguably, such organization and editing falls within the Newspaper’s discretion, as long as the final product was not published with reckless disregard for truth or falsity. See Janklow, 788 F.2d at 1304; Strada, 193 Conn. at 326, 477 A.2d at 1012. There was no evidence the Newspaper doubted the accuracy of the published articles. To the contrary, quotations and documents were rechecked, interviews and notes were reviewed, statements often were presented with cautionary language, and stories that could not be independently verified were not used. Journalism Professor Holsinger testified no journalism standards were violated in the reporting or editing of the articles. Indeed, he also stated at trial “[t]his is a textbook model of how investigative reporting should be done.” The Newspaper editors’ refusal to meet with Diesen apparently was in accordance with standard journalism policy. Although Diesen was free to meet with the reporter again at any time and to provide the Newspaper with additional information, he refused to do so. Further, the concern demonstrated by the Newspaper in reviewing the articles with legal counsel before publication contravenes a finding of actual malice. Under such circumstances, “the First Amendment forbids penalizing the press for encouraging its reporters to expose wrongdoing by * * * public figures.” Tavoulareas, 817 F.2d at 796 (footnote omitted).
“Although credibility determinations are reviewed under the clearly erroneous standard, * * * the reviewing court must ‘examine for [itself] the statements in issue and the circumstances under which they were made to see * * * whether they are of a character which the principles of the First Amendment * * * protect.’ ” Harte-Hanks, — U.S. at -, 109 S.Ct. at 2696 (citation omitted) (quoting New York Times, 376 U.S. at 285, 84 S.Ct. at 728). Further, “[t]he question whether the evidence in the record * * * is sufficient to [454]*454support a finding of actual malice is a question of law [based] on the unique character of the interest protected by the actual malice standard.” Id. at -, 109 S.Ct. at 2694-95 (citation and footnote omitted). The dissent’s discussion of additional facts, which are clearly distinguishable from those in Harte-Hanks, does not change our discernment from the record that actual malice was not established here as a matter of law.
IV.
Although the propriety of the punitive damages award was briefed and argued by the parties, ruling as we do, we need not reach that issue.
Reversed.