Yes, I did read it, thanks for being condescending and violating HN guidelines. As I said already, I sat on the jury for a similar case that did go to trial in California so your rationale for thinking this wouldn't doesn't make sense to me and seems based on no actual experience. This is not an instance of someone simply quoting another person - the individual who posted the memo online did so deliberately to cause harm and bring unwanted media attention and public hatred toward another individual, which pretty much ruined his life. Further, your focus on the "outrageous" portion only shows you're cherry picking what you want this particular tort to say rather than the whole definition. So yes, it is reckless disregard under that standard and any lawyer could probably bring it to trial if they so desired. Whether the jury would find the tweeter guilty or not is another matter.