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Here are a few entries in the ALR regarding public figure as it relates to criminal defendants:

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For purposes of defamation claim, individuals who have been accused or convicted of crimes may be classified as public figures. Skakel v. Grace, 5 F. Supp. 3d 199, 42 Media L. Rep. (BNA) 1437 (D. Conn. 2014).

In action by woman who alleged she was defamed in magazine article, court did not err in determining that woman was limited-purpose public figure with respect to article at issue, where woman had been convicted of tax evasion with regard to thousands of dollars she had received but not reported as income from wealthy widower, where her trial had generated considerable amount of local publicity, as well as some national publicity, in which woman had participated, where after her conviction and while imprisoned before her conviction was overturned woman had met writer with whom she agreed to work on book, where focus of magazine article was how woman had proceeded to take writer “on frightening journey,” how woman’s relationship with writer soured, and how she made demands and threats, where article addressed at length woman’s tax-evasion conviction and its subsequent reversal, where it also delved into writer’s interest in writing proposed book, quoting writer as being suspicious of government’s interest in pursuing tax-evasion charges, where only after reading one-third of article could reader find discussion on relationship between woman and writer, where writer’s proposed book was directly related to tax controversy, and where woman’s interest in proposed book stemmed from desire to present her side of tax case and clear up her image. Harris v Quadracci (1995, CA7 Wis) 48 F3d 247, 23 Media L R 1296.

Stepfather of murdered child was a limited purpose public figure, for purposes of his defamation action alleging that he was falsely charged with the murders of his stepson and two other children in a letter posted on a singing group’s website and statements made by a singer at a rally, and thus he was required to prove actual malice by clear and convincing evidence; issues involved were matters of public concern, and stepfather publicly advocated his lack of involvement in the murders well before defendants made the alleged defamatory statements, he had full access to the media, and he attempted to influence public opinion and the authorities. Hobbs v. Pasdar, 682 F. Supp. 2d 909 (E.D. Ark. 2009).

Report on national cable television news network allegedly suggesting that family of child murder victim could have been involved in murder involved a matter of public concern, and thus actual malice standard applied to family’s defamation action against network under Colorado law; murder investigation had been subject to unprecedented media attention. Ramsey v. Fox News Network, L.L.C., 351 F. Supp. 2d 1145 (D. Colo. 2005).

Under District of Columbia law, prisoner who brought defamation action against legal publisher was a “limited-purpose public figure” for First Amendment purposes; there was public controversy concerning shootout upon which prisoner’s murder convictions were based, as well as about underlying issues of taxation and federal government power, as the press extensively covered shootout, all stages of prisoner’s trial, and prisoner’s association with anti-tax and anti-government movements, prisoner assumed a public role in the controversy when he used his access to the press to promote his cause and worked to maintain his place in the spotlight, giving extensive interviews for a documentary, publishing a book about his case, and maintaining a personal website, and publisher’s allegedly defamatory report about prisoner’s conviction and his petition to have his sentence vacated related to his role in the controversy. U.S. Const. Amend. 1. Kahl v. Bureau of National Affairs, Inc., 856 F.3d 106 (D.C. Cir. 2017) (applying District of Columbia law).

Inmate, who brought action for defamation and other torts, was a limited purpose public figure, and was therefore required to clearly and convincingly prove “actual malice” on part of newspaper and author, who wrote newspaper articles on topic of online “dating” by incarcerated felons which featured inmate; articles addressed matters of public concern, inmate, who placed personal advertisement on Web site, voluntarily injected himself into particular public controversy, and inmate was highlighted in articles because his advertisement was particularly misleading and controversial. LaChance v. Boston Herald, 78 Mass. App. Ct. 910, 942 N.E.2d 185 (2011).

Subject in book depicting activities of a group of criminals was a limited-purpose public figure and, thus, was required to prove actual malice to recover any damages in his defamation suit against book’s author, given subject’s admissions with respect to his prior criminal convictions and public records regarding his prior criminal involvement. Berkery v. Estate of Stuart, 412 N.J. Super. 76, 988 A.2d 1201 (App. Div. 2010).

Subject of newspaper articles about subject’s attempts to stop author from publishing a book that named subject as a member of a criminal gang and subject’s defamation action against author was a limited-purpose public figure and, thus, was required to prove actual malice to recover any damages in his defamation action against writer of articles, publisher of newspaper, and owner of publisher, given subject’s admissions with respect to his prior criminal convictions and public records regarding his prior criminal involvement. Berkery v. Kinney, 936 A.2d 1010 (N.J. Super. Ct. App. Div. 2007).