Wolston v. Reader's Digest Ass'n - 443 U.S. 157, 99 S. Ct. 2701 (1979)

Rule:

A private individual is not automatically transformed into a public figure just by becoming involved in or associated with a matter that attracts public attention.

Facts:

In 1957 and 1958, Ilya Wolston’s aunt and uncle, Myra and Jack Soble, were the subject of an investigation to find Soviet intelligence agents in the United States. On one occasion, Wolston failed to respond to a subpoena and pleaded guilty to a contempt charge. The incident was publicized in newspapers, but Wolston succeeded in returning to life as a private citizen. In 1974, Reader’s Digest Association published a book by John Barron about the KGB and Soviet agents in the United States. The book and its index identified Wolston as a Soviet agent. Wolston sued the author and publishers for libel in district court. The district court granted summary judgment for the Association and held that Wolston was a “public figure” and had to prove the Association acted with actual malice to prevail in a libel suit. The Court of Appeals for the District of Columbia Circuit affirmed.

Issue:

Is Wolston a public figure and required to prove actual malice in order to win a libel suit?

Answer:

No.

Conclusion:

The Supreme Court held that Wolston met neither of the requirements to be considered a public figure. Wolston was not a figure of “persuasive power and influence,” nor did he thrust himself to the forefront of popular controversy. The Court held that an individual does not become a public figure merely by attracting public attention, and such individuals should not lose the protection afforded to private individuals. The court reversed the grant of summary judgment to respondents, author and publishers of a book, in petitioner's action for libel, holding that petitioner was not a public figure and was not required to meet the actual malice standard in order to recover from respondents.