Traditional editorials like, say, in the National Review or NYT, may well be wrong, but at least they're trying to be right. Likewise, the "independence" of fact-checking orgs doesn't lie in being "non-partisan" so much as making speaking truly an overriding value.
(I'd concede that Breitbart in particular probably isn't a paradigm example of a fake news outlet, but it's obviously on the spectrum.)