Waldbaum v. Fairchild Publications, Inc.

Waldbaum (plaintiff), CEO of a food cooperative known industry-wide for innovative supermarket practices and featured in trade journals, was ousted by his board after five years; a trade publication owned by Fairchild (defendant) reported the ouster and noted the cooperative had been losing money. Waldbaum sued for libel, claiming the article falsely portrayed him as a poor businessman, and Fairchild sought summary judgment on the ground he was a limited-purpose public figure who could not show actual malice.

Whether a person can be considered a public figure for limited purposes under libel law.