§ 6.4.4.5.3 ACTUAL MALICE AND PUBLIC FIGURES.

• Jurisdiction: Arizona

§ 6.4.4.5.3 Actual Malice and Public Figures. The higher standard of fault, actual malice, is also required for "public figures." In Gertz,⁶⁶ the United States Supreme Court generally defined public figures as persons who voluntarily inject themselves into a limited range of public issues; public figures have generally "thrust themselves to the forefront of particular public controversies in order to influence the resolution of the issues involved" and in so doing, "invite attention and comment."⁶⁷ In Arizona, public figure status has been applied to an organized crime enforcer who had "turned State's evidence against an Arizona crime boss."⁶⁸ In Dombey v. Phoenix Newspapers, Inc.,⁶⁹ a private insurance agent who was the agent...