Carl Critic has just announced his choices of the worst Hollywood actresses of the year, and Stella Starr has been named the worst of the worst. Carl's announcement, made in his weekly column titled "Random Musings by Carl Critic" and published in the local paper, claims that he believes her to have the least amount of talent in the movie industry and that she "can't act her way out of a paper bag." When Stella reads Carl's column, she immediately starts to cry hysterically and then decides to sue him. Does she have a valid case of libel?