Inc. Gertz v. Robert Welch

Last, the Court addressed the respondent's argument that Gertz was in fact either a public figure or a public official. In the Court's view, he was neither. Unless all lawyers were regarded as "public officials," Gertz clearly did not belong in that category. As to the "public figure" designation, the Court identified two types: all-purpose and limited-purpose. The all-purpose public figure was famous (or notorious) in all contexts. The limited-purpose public figure was well-known, either voluntarily or not, in the context of one particular public controversy. Despite the fact that Gertz was active in professional organizations and civic groups, he was not well-known enough to qualify as a public figure.

The Court therefore reversed the lower court's ruling. The New York Times standard did not apply in this case. The original jury award of $50,000 had to be reconsidered, though, because the jury had imposed strict liability.