Khawar v. Globe International, Inc.

Khawar (plaintiff), a private freelance photographer photographed near Robert Kennedy shortly before his assassination, was falsely named in a Globe (defendant) tabloid article, based on an unsubstantiated book theory, as the actual assassin — despite extensive investigations and Sirhan Sirhan's conviction establishing Sirhan as the lone assassin. The jury found Globe's republication false, defamatory, negligent, and made with actual malice, awarding Khawar substantial damages; the Court of Appeal affirmed, finding Khawar a private figure ineligible for the neutral-reportage privilege, and Globe sought review.