7.3.2 Private Figure|Matter of Public Concern.

• Jurisdiction: Arizona

7.3.2 Private Figure/Matter of Public Concern.

In cases involving media defendants, the U.S. Supreme Court has held that private figures must prove actual malice when the alleged defamatory speech touches on an issue of public concern.²⁵ In a case involving a non-media defendant, the Arizona Court of Appeals held that a private figure plaintiff could demonstrate libel per se and recover presumed damages without having to prove actual malice.²⁶

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Notes:

^[25] Philadelphia Newspapers, Inc. v. Hepps...