A public figure is a person who has achieved a certain degree of fame in the public sphere. The term has significance for United States civil law because it affects the resolution of certain types of lawsuits. These people are expected to tolerate more scrutiny than others, and consequently have more difficulties in winning cases surrounding the issues of defamation and privacy.
Ideas associated with this category of people have figured prominently in rulings on defamation cases by the United States Supreme Court. These rulings are generally based on interpretations of the First and Fourteenth Amendments to the United States Constitution. They deal both with protections of free speech and with the federal government's ability to regulate states.
Several sources identify New York v. Sullivan (1964) as the first case to create the public figure standard. The case concerned a dispute between the New York Times and certain public officials in Alabama: particularly L. B. Sullivan, the Montgomery Public Safety commissioner. The government of Alabama sued the newspaper for running an advertisement allegedly defaming Sullivan and others. The United States Supreme Court overruled a decision, favorable to Sullivan, by the Alabama Supreme Court. Their reasoning was that because Sullivan had already placed himself into the public sphere, his case required a higher burden of proof than had been demonstrated or was usually necessary.
In the same case, the Supreme Court also originated a standard called "actual malice," the criterion necessary to rule against a public figure in a defamation case. In a typical libel or slander case, damaging a person's reputation with incorrect facts might be sufficient for a ruling. In order to lose a suit to someone designated as a public official, however, the defendant must have acted with actual malice, or "knowledge that statements are false or in reckless disregard of the truth." New York v. Sullivan did not contain the precise phrase "public figure," but it is cited as controlling precedent because the actual malice standard came to govern future cases concerning this type of person.
Later rulings created an intermediate category of "limited public figures." Cases such as Gertz v. Welch (1974) left open room for discretion in certain types of situation. In particular, the category was used to describe someone who had been thrust into the public sphere at a particular time for a particular reason. The Court ruled that a person could be designated a public figure insofar as they had become relevant, but that this status did not necessary apply to them in all of their affairs, for the rest of their lives. The Gertz ruling also emphasized that individual states could, to some degree, make their own determinations about defamation law.
