The Milkovich v. Lorain Journal decision teaches that ______.

a. newspaper columns and columnists are immune from successful libel claims
b. in spite of being forums for opinion, newspaper columns and columnists may be targets of successful libel claims
c. letters to the editor are protected by the opinion defense
d. neutral reportage is limited in its scope

b. in spite of being forums for opinion, newspaper columns and columnists may be targets of successful libel claims