Section 5.26 Limited Purpose Public Figures

• Library: Tort Law 2016

(2) (§5.26) Limited Purpose Public Figures

In Wolston v. Reader’s Digest Ass’n, Inc., 443 U.S. 157 (1979), the Supreme Court held that limited public-figure status requires both newsworthiness of the underlying matter and participation by the plaintiff in that newsworthy matter. See also Lundell Mfg. Co. v. Am. Broad. Cos., 98 F.3d 351, 363–64 (8^th Cir. 1996). In making this determination, the courts have generally followed a three-part test. First, there must be a public controversy, an issue that is being publicly debated the outcome of which impacts the public in an appreciable way. Second, the plaintiff must have taken some act designed to influence the resolution of those issues or thereby become directly involved in them. Finally, the alleged defamation must be germane to the plaintiff’s involvement in the controversy...