re appropriate than the actual malice standard. Thus, the plaintiff had to prove that the defendant publishers engaged in "highly unreasonable conduct constituting an extreme departure from the standards of investigation and reporting ordinarily adhered to by responsible publishers." The Court, however, failed to define the term "public figure," noting only that the plaintiff in this case was the subject of a substantial amount of public interest.
The Court finally defined the term "public figure" in 1974, when it considered a case involving an attorney representing a family in a highly publicized wrongful death action filed against the Chicago Police Department. The attorney had been the subject of an article published by the John Birch Society falsely accusing him of extensive Communist Party activities. The lower court found the defendants liable for defamation, despite the fact that Communism was a topic of public concern. The Supreme Court upheld this ruling, holding that courts have no business deciding whether particular information relates to
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