It follows that if the plaintiff cannot prove “actual injury,” he cannot recover any damages, unless he can show that the publication was made with knowledge of its falsity or with reckless disregard for the truth. There is no constitutional protection for publications made with “knowl-edge or reckless falsity,” and hence, the plaintiff is entitled to whatever recovery is permitted under state law in such cases (i.e., “presumed” or general damages and even punitive damages in appropriate cases). Note that this approach is simply a restatement of the general rule in torts that damages must be proved in negligence actions (see infra, III.E.) but usually are not required where the defendant is more culpable, such as for intentional torts