If a person falsely accuses a public figure of cheating at chess, then takes actions that costs the public figure monetary damage. If despite lack of evidence, the person has a bona fide belief that there was cheating. Could that ever qualify as Reckless disregard for the Truth?
The fuller statement is reckless disregard for the truth or falsity of the statement.
The reckless disregard for truth element in defamation claims requires a plaintiff to show that the defendant had serious doubts about the accuracy of the material. St. Amant v. Thompson, 390 U.S. 727 (1968). A summary of the holding of this U.S. Supreme Court case explains its holding:
Recklessness requires a higher level of proof than ordinary negligence, so the reasonable-care standard is not appropriate. The defendant cannot avoid liability by testifying that he had a subjective belief that the statements were true. Instead, the jury must find through its consideration of all of the relevant evidence that the statements had been made in good faith. There was no evidence in this situation that St. Amant had entertained serious doubts about the veracity of Albin's accusations. The absence of an effort to check their facts did not rise to the level of actionable conduct.
This decision clarified the requirement of malice in defamation lawsuits regarding matters of public concern. It does not mean ill will but rather knowledge of the information's falsity or reckless disregard of the truth.
This means that if you just make something negative up without having any idea whether it is true or not, you can be guilty of defamation if it turns out to be false under U.S. law.
But, reliance on a third-party whom you believe to have a basis for their allegations and republishing the third-party's claim is not reckless disregard for the truth if you have any reason to believe that the third-party is credible. One doesn't have to have personal knowledge of the facts.
One can also have a reasonable factual basis for having a belief without knowing for sure that something is true from evidence that would be admissible in court or would definitely prove the allegation.
For example, if the chess player's moves were atypical of that chess player's previous plays and showed insights that player had not shown before, that would provide a basis for the statement that would overcome a reckless disregard claim.
the person has a bona fide belief that there was cheating. Could that ever qualify as Reckless disregard for the Truth?
The defendant's belief being bona fide negates reckless disregard of the truth. However, the allegation of good faith tends to be unpersuasive if the defendant does not offer credible elements on which to premise his false statement(s) of fact.
A defendant's allegation in the sense of "I just knew, don't ask me why" is likely to lead to a finding of reckless disregard of the truth because there is no way to prove that there was intuition or even a genuine belief.