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When determining whether a person is a public figure, the court first must ask whether the plaintiff is a public figure for all purposes. A plaintiff can be found to be a general public figure only after a clear showing of general fame or notoriety in the community, and pervasive involvement in the affairs of society. In other words, a general public figure is a well-known "celebrity," his name a "household word." The public recognizes him and follows his words and deeds, either because it regards his ideas, conduct, or judgment as worthy of its attention or because he actively pursues that consideration.
Eric Waldbaum filed suit against Fairchild Publications, Inc. (Fairchild) after Waldbaum was dismissed as president and chief executive officer of a diversified consumer cooperative that, during Waldbaum’s tenure, ranked as the second largest cooperative in the country. Waldbaum played an active role as an advocate for setting policies and standards within the supermarket industry. Waldbaum asserted a libel action against Fairchild for printing an article about his dismissal in which Fairchild claimed Waldbaum’s company had been losing money and retrenching. The district court granted Fairchild’s motion for summary judgment on the grounds that there was no actual malice and that Waldbaum was a limited public figure.
Was Waldbaum considered a limited public figure?
Affirming, the court held that Waldbaum was a limited public figure because his company was an innovative company that was often the subject of news reports and Waldbaum was known as a leading advocate of certain precedent-breaking policies.