While jurors were still deliberating, U.S. District Judge Jed Rakoff announced his decision Monday. He stated that once the jury reached a decision, he would dismiss Ms. Palin's complaint.
Judge Rakoff's decision came after a rare libel trial that delved into the inner workings of a major news organization. Ms. Palin and prominent Times figures testified in the trial, which concluded last week.
Allowing the jury to complete its work would benefit an appeals court when reviewing the case, according to the judge, and could help avoid the need for a retrial if his decision is overturned.
Ms. Palin filed a lawsuit against the Times in 2017, just two weeks after it published an editorial about gun violence and political rhetoric in the aftermath of a shooting at a congressional baseball practice. The piece used the phrase "political incitement" incorrectly to suggest that an ad circulated by Ms. Palin's political action committee inspired a shooter who killed six people and injured Arizona Democrat Rep. Gabrielle Giffords in 2011.
Within hours, the Times corrected the editorial, removing the incitement claim and issuing an apology to its readers via Twitter.
The decision came in response to a motion filed by the Times, which argued that it was entitled to win as a matter of law because no reasonable juror could conclude it defamed Ms. Palin, the 2008 Republican vice presidential nominee and former Alaska governor.
Judge Rakoff ruled that Ms. Palin had failed to establish that the newspaper acted with actual malice, such as reckless disregard for the truth, an essential element that public figures such as Ms. Palin must demonstrate in order to prevail.
According to the judge, the law required Ms. Palin to present "strong, affirmative evidence that, prior to publishing, the author either had actual knowledge that the challenged statements were false or at least a conscious recognition that they were."
"This is an example of very unfortunate editorializing on the Times' part," he said, adding that the law sets a very high standard that Ms. Palin did not meet.
The ruling, according to Times spokeswoman Danielle Rhoades Ha, reaffirmed "a fundamental tenet of American law: public figures should not be permitted to use libel suits to punish or intimidate news organizations that make, acknowledge, and promptly correct unintentional errors."
The attorneys for Sarah Palin did not respond to a request for comment.
Public figures have a poor chance of succeeding in defamation claims against news organizations, and many lawsuits are dismissed before trial.
Some conservatives have sought to limit the scope of First Amendment protections for the media, and the Palin case was seen as a potential test of that effort by legal observers.
Ms. Palin had to prove by clear and convincing evidence that the Times and its then-opinion editor, James Bennet, acted with actual malice, which meant they either knowingly published a false statement or showed a reckless disregard for the truth, under landmark legal rules established by the Supreme Court nearly 60 years ago.
Some attorneys who were not involved in the case were perplexed by Judge Rakoff's decision to announce a future dismissal ruling rather than wait for the jury to finish.
"It's difficult to understand why he didn't keep this in his pocket until the jury returned a verdict," said George Freeman, executive director of the Media Law Resource Center and a former Times attorney.
Another concern, expressed by First Amendment attorney Floyd Abrams, is that the jury will learn about the judge's decision from news reports, which could taint a verdict.
Judge Rakoff's decision on Monday was his second rejection of Ms. Palin's claims. In 2017, he ruled that her lawsuit should be dismissed before it went to trial. However, two years later, a federal appeals court overturned the decision and reinstated the case.
In the 2017 editorial, Palin's lawyer, Kenneth Turkel, claimed that the Times and its staff treated conservatives differently and turned a blind eye to the truth.
"Whether they could prove it or not, they were going to publish this story," he said during Friday's closing arguments.
An attorney for the Times, David Axelrod, told jurors that Mr. Bennet's and the paper's quick corrective actions undermined the notion that there was a conspiracy to publish something false about Republicans or Ms. Palin.
Ms. Palin sought monetary compensation for the embarrassment and trauma she claimed she experienced as a result of the editorial. Although the suit did not specify an amount, Ms. Palin's attorney asked jurors on Friday to determine fair compensation and suggested that at least nominal damages be awarded.
Judge Rakoff barred the jury from considering punitive damages against the Times last week, ruling that there wasn't enough evidence to prove the editorial was motivated solely by a desire to harm Ms. Palin.
Jurors will reconvene on Tuesday morning to continue their deliberations. As they were leaving for the evening, the judge wished them a happy Valentine's Day and offered a gentle reminder: If you see anything about this case in the media, just turn away, he said.
"I certainly considered the possibility of waiting until after the jury had rendered its verdict," Judge Rakoff said Monday outside the presence of the jurors. "However, the more I thought about it over the weekend, the more I realized it was unjust to both sides."