In which of the following scenarios would the journalist most easily be protected from a libel claim?

The information in the article was true. But it cost the plaintiff thousands of dollars in lost revenue
The information in the article came from the reporter overhearing a private conversation between the mayor and vice mayor during a break in the city council meeting. The mayor said he heard a local business owner was going to lose his business license because of some failed inspections. The reporter writes a blurb in the paper, quoting the mayor, but the information ends up being false
The facts are incorrect, but the reporter has a strong argument that it was an opinion piece, and not a regular news story. The reporter is normally a news reporter and not an opinion columnist.