If a plaintiff in a libel or slander action qualifies as a public figure, he or she must show that the libelous or slanderous conduct of the defendant was motivated out of actual malice as required in the case of NEW YORK TIMES CO. V. SULLIVAN, 376 U.S. 254, 84 S.Ct. 710, 11 L.Ed.2d 686 (1964).
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