The Boston Globe reports that the U.S. Court of Appeals for the First Circuit yesterday ordered a new trial for the Phoenix, which had been ordered to pay $950,000 to former Maryland prosecutor Marc Mandel in a Dec. 2004 decision. The case stems from a 2003 article about custody disputes by former staff writer Kristen Lombardi; the story included allegations that Mandel had molested his children from two marriages. The U.S. Court of Appeals ruled that the trial judge should have examined more evidence before deciding that Mandel was not a public figure.