Waldbaum v. Fairchild Publications, Inc.
627 F.2d 1287 (1980)
Legal Analysis
Legal analysis from Dean's Law Dictionary will be displayed here.
Nature Of The Case
This section contains the nature of the case and procedural background.
Facts
P became president and chief executive officer of Greenbelt Consumer Services, Inc. (Greenbelt). Greenbelt is a diversified consumer cooperative that, during Waldbaum's tenure, ranked as the second-largest cooperative in the country. P played an active role not only in the management of the cooperative but also in setting policies and standards within the supermarket industry. P held several meetings, to which press and public were invited, on topics varying from supermarket practices to energy legislation and fuel allocation. He pursued a vigorous policy of consolidating Greenbelt's operations to eliminate unprofitable outlets. These actions generated considerable comment on both Greenbelt and P in trade journals and general-interest publications. Greenbelt's board of directors dismissed P. D's trade publication ran an item on P's ouster on page 35 of its March 22 issue. The five-sentence article stated at one point that Greenbelt 'has been losing money the last year and retrenching.' P filed a libel action. P contended that Greenbelt had not been losing money or retrenching and that this allegedly false report damaged his reputation as a businessman. P sought actual and exemplary damages totaling $75,000. D moved for summary judgment. It argued that P was a public figure and because he had admitted the absence of 'actual malice.' The court granted the motion holding that P was a limited public figure. P appealed.
Issues
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Holding & Decision
The court's holding and decision will be displayed here.
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