Waldbaum v. Fairchild Publications, Inc.
United States Court of Appeals for the District of Columbia Circuit
627 F.2d 1287 (1980)
Under libel law, a person can be a public figure for limited purposes. This classification pertains to individuals who involve themselves in public controversies, becoming public figures within a specific context or range of issues. Despite not being widely recognized or famous, such individuals are subject to the higher standard of proving actual malice to recover for defamation.
Relevant Facts
Eric Waldbaum, the plaintiff, was the CEO of Greenbelt Consumer Services, Inc. (Greenbelt), a food cooperative. Waldbaum was known for implementing innovative practices in the supermarket industry and was featured in trade journals and general media. After five years, Greenbelt's board ousted Waldbaum. A supermarket trade publication, owned by Fairchild Publications, Inc. (Fairchild), the defendant, covered this ouster, reporting that Greenbelt had been losing money and retrenching during the previous year. Waldbaum sued Fairchild for libel, claiming the article falsely portrayed him as a poor businessman. Fairchild moved for summary judgment, arguing that Waldbaum was a public figure, hence requiring a standard of actual malice for libel, which Waldbaum admitted Fairchild did not have.
Issue
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Holding & Reasoning
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Concurrence
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Dissent
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Last updated:
December 8, 2023
Judicial Opinion
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Procedural History
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Citations
627 F.2d 1287 (1980)