Au contraire
Mike, if someone were to give you a newspaper and tell you that there's a libelous article on page 7, would you sue them for defamation? That's the same principle.
I have two major problems with the logic used in the decision:
1. While I'm not aware of the legal definitions involved, I know that public communications (i.e. publication) and private communcations are not the same thing, in realistic terms. How does sending a private email affect the general public opinion of someone to the point of defamation?
2. Intent is virtually impossible to discern when the actions are not so self-evident. For example, striking another person in the head with a lead pipe is pretty clear cut intent. Can the same really be said for including a link to an article in an email? How can you know the article was read and understood by the sender? How many times have you or someone you've known sent an article to a friend just from reading the headline or abstract? Not sure there's any way to clearly know the intent of the emailed link without more actions to demonstrate things clearly.
It's still possible that the state laws in use in the case provide for wider interpretation, but that a tremendous shame if it turns out to the case. And there's absolutely nothing fair about a ruling based on incorrect notions of what is public and what is clear intent.