Lohrenz v. Donnelly

Carey Lohrenz (plaintiff) became one of only two female F-14 combat pilots amid an intense public controversy over women in combat roles, a controversy she was aware of and knew her role would place her at the center of. After the other female combat pilot died in a training exercise, activist Elaine Donnelly (defendant), who had campaigned against women in combat, began publicly questioning Lohrenz's competence as a pilot. After losing her pilot position, Lohrenz sued Donnelly for defamation, and the district court granted Donnelly summary judgment, finding Lohrenz a limited-purpose public figure who failed to show actual malice; Lohrenz appealed.