In defining a public figure, the Court said that a public figure is one who has "assumed roles of especial prominence in the affairs of society." The Court added that some individuals become public figures for "all purposes" because they have achieved such a high degree of fame or notoriety in the community at large. However, the Court said that very few persons meet these criteria. More common are those individuals who voluntarily "[thrust] themselves to the forefront of particular public controversies in order to influence the resolution of the issues involved." These individuals are public figures only with regard to the limited range of issues for they are prominent. In addition, the frequency of individuals becoming public figures involuntarily is "exceedingly rare."
Since the Gertz decision, the Supreme Court has decided only a few cases in which the plaintiff's status as a public figure has been at issue. In three of the cases, the Court found that the plaintiff was not a public figure and therefore did not have to prove actual malice in order to recover damages. However, the Court did not clarify the principles established in Gertz, instead analyzing the cases strictly according to the facts in each case. According to some commentators, the Court failed to articulate workable standards in these three cases which were consistent with Gertz and New York Times.
The first of these cases involved the wife of a member of the Firestone family, which was well-known for the manufacture of tires. Time magazine published an allegedly defamatory report on the divorce proceedings between the woman and her husband. This divorce was the subject of considerable news coverage and the woman had held several press conferences to discuss her side of the legal proceedings. According to the Court, the woman was not a "limited purpose" public figure because even a divorce proceeding involving wealthy individuals was not a publi...
The Public Figure Doctrine. (1969, December 31). In LotsofEssays.com. Retrieved 15:44, October 10, 2015, from http://www.collegetermpapers.com/viewpaper/1303913210.html