Hutchinson v. Proxmire - 443 U.S. 111, 99 S. Ct. 2675 (1979)

Rule:

For the most part those who attain the status of a public figure assume roles of especial prominence in the affairs of society. Some occupy positions of such persuasive power and influence that they are deemed public figures for all purposes. More commonly, those classed as public figures have thrust themselves to the forefront of particular public controversies in order to influence the resolution of the issues involved. In either event, they invite attention and comment. 

Facts:

Respondent United States Senator publicizes examples of wasteful governmental spending by awarding his "Golden Fleece of the Month Award." One such award was given to federal agencies that had funded petitioner scientist's study of emotional behavior in which he sought an objective measure of aggression, concentrating upon the behavior patterns of certain animals. The award was announced in a speech prepared with the help of respondent legislative assistant, the text of which was incorporated in a widely distributed press release. Subsequently, the award was also referred to in newsletters sent out by the Senator, in a television interview program on which he appeared, and in telephone calls made by the legislative assistant to the sponsoring federal agencies. Ronald Hutchinson sued respondents in Federal District Court for defamation, alleging, inter alia, that in making the award and publicizing it nationwide, respondents had damaged him in his professional and academic standing. The District Court granted summary judgment for respondents, holding that the Speech or Debate Clause afforded absolute immunity for investigating the funding of Ronald Hutchinson’s research, for the speech in the Senate, and for the press release, since it fell within the "informing function" of Congress. The court further held that Hutchinson was a "public figure" for purposes of determining respondents' liability; that respondents were protected by the First Amendment thereby requiring petitioner to prove "actual malice"; and that based on the depositions, affidavits, and pleadings there was no genuine issue of material fact on the issue of actual malice, neither respondents' failure to investigate nor unfair editing and summarizing being sufficient to establish "actual malice." Finally, the court held that even if petitioner were found to be a "private person, " relevant state law required a summary judgment for respondents. The Court of Appeals affirmed, holding that the Speech or Debate Clause protected the statements made in the press release and newsletters and that, although the followup telephone calls and the statements made on television were not protected by that Clause, they were protected by the First Amendment, since petitioner was a "public figure," and that on the record there was no showing of "actual malice."

Issue:

Was Hutchinson a “public figure”, thus, the "actual malice" standard apply to him?

Answer:

No

Conclusion:

Reversing the district court and the appeals court, the United States Supreme Court held that Hutchinson was not a "public figure," and therefore the "actual malice" standard did not apply to him. In addition, the Court held that the Speech and Debate Clause of the United States Constitution did not protect respondents for defamatory statements they made or might make. That meant that the libelous remarks made by respondents in followup telephone calls to executive agencies, and in the television and radio interview, were not protected.