Wolston v. Reader's Digest Association, Inc. (1978)
- Docket
- 78-5414
- Decided
- 1978-01-01
Summary
Question: Is Wolston a public figure and required to prove actual malice in order to win a libel suit? Conclusion: No. Justice William H. Rehnquist delivered the opinion of the 8-1 majority. 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. In his concurring opinion, Justice Harry A. Blackmun wrote that the majority’s decision defined “public figure” too narrowly, but the intervening years between Wolston’s publicity and the libelous statement sufficed to consider him a private citizen. Blackmun argued that the timing of the potentially libelous statement relative to the event that brought about public scrutiny of an individual is relevant in libel cases. Justice Thurgood Marshall joined in the concurrence. Justice William J. Brennan, Jr. wrote a dissent and argued that, because the issue of Soviet espionage remained a relevant issue in 1974, the intervening years did not diminish Wolston’s status as a public figure. He also wrote that the district court erred in granting summary judgment.