Wells v. Liddy

Wells (plaintiff), a DNC secretary whose desk key the Watergate burglars carried, was later named in books alleging the break-in sought to uncover DNC-organized prostitution and that evidence was locked in her desk; Liddy (defendant) repeated these allegations publicly. The trial court, treating Wells as an involuntary public figure, granted Liddy summary judgment for lack of proof of actual malice, and Wells appealed.

Whether a person connected to a public controversy only through compelled legal process, rather than voluntary participation, must prove actual malice to recover for a defamatory statement injuring her reputation.