What made the burden of proof in this case more difficult?

Transcript:

Well, Jesse Ventura’s a public figure, so we have the actual malice standard. So not only do we have to prove that the story was false, we have to prove that Kyle knew it was false when he wrote it or believed it not to be true. And that – the jury was out for almost a week, and the questions they asked indicated that that’s the issue that they focused in on.