Deer unearthed clear evidence of falsification. He found that not one of the 12 cases reported in the 1998 Lancet paper was free of misrepresentation or undisclosed alteration, and that in no single case could the medical records be fully reconciled with the descriptions, diagnoses, or histories published in the journal.

Who perpetrated this fraud? There is no doubt that it was Wakefield. Is it possible that he was wrong, but not dishonest: that he was so incompetent that he was unable to fairly describe the project, or to report even one of the 12 children’s cases accurately? No. A great deal of thought and effort must have gone into drafting the paper to achieve the results he wanted: the discrepancies all led in one direction; misreporting was gross.

Several Fourth Circuit cases make clear that including a remark by one of the key participants in a heated public-health debate stating that his adversary "lies" is not an actionable defamation. Indeed, both the nature of the statement -- including that it was quoting an advocate with a particular scientific viewpoint and policy position -- and the statement's context -- a very brief passage in a lengthy description of an ongoing, heated public health controversy -- confirm that this is a protected expression of opinion.