WFAA-TV, Inc. v. McLemore

Reporter McLemore (plaintiff) covered a federal raid on the Branch Davidian compound live from the scene, helped evacuate wounded agents, and later gave numerous interviews portraying himself heroically. When WFAA-TV (defendant) reported allegations that a media member had tipped off the Davidians and noted McLemore's presence at the raid, he sued for defamation; the trial court denied WFAA-TV's summary judgment motion (based on the public-figure/actual-malice defense), and the court of appeals affirmed. WFAA-TV sought review.

Whether a public figure or official asserting defamation must prove the defendant published a defamatory statement with actual malice -- knowledge of falsity or reckless disregard for the truth.