A freelancer is more likely to be held personally liable than a FTE. But, as you rightly question, - it depends entirely on what the cause of action is, what the facts are, and whether or not there's an agency or employee relationship.
Usually the publisher throws in the towel and by doing so, implicates/exposes/admits the libel of the journalist. Should the freelancer/journalist feel strongly aggrieved, exposed and undermined by this - then it's down to how deep their pockets are and/how strong their evidence is. Assuming there is no punishment - then not very.