Thomas M. Cooley Law Sch. v. Kurzon Strauss, LLP - 759 F.3d 522 (6th Cir. 2014)

Rule:

There are two kinds of "public figure" plaintiffs: a "limited-purpose" public figure and a "general-purpose" public figure. A limited-purpose public figure is a public figure with respect to a limited range of issues, and one achieves that status by voluntarily injecting himself into a particular public controversy. A general-purpose public figure is one who attains such pervasive fame or notoriety that he becomes a public figure for all purposes and in all contexts.

Facts:

Plaintiff law school claimed that defendants published defamatory statements regarding plaintiff's institution, causing $17 million in damages. The defendants posted a statement on the website “JD Underground” which provided that the plaintiff grossly inflated its post-graduate employment data and salary information, and defrauded unwitting students. In granting defendants' motions for summary judgment, the district court held that the plaintiff was a limited-purpose public figure and that the record would not allow a reasonable jury to conclude that defendants published the challenged statements with actual malice.

Issue:

Did the district court properly grant the summary judgment?

Answer:

Yes.

Conclusion:

The plaintiff was properly classified as a limited-purpose public figure because defendants showed the existence of a "public controversy" regarding whether law schools were reporting accurate post-graduate employment data and whether law school graduates could afford to pay back student loans, and the school voluntarily injected itself into the public debate by publicly responding to a question and reports. The evidence did not create a genuine issue of material fact on whether defendants published the challenged statements with actual malice.