Atlanta Journal-Constitution v. Jewell
Georgia Court of Appeals
555 S.E.2d 175 (2001)
Richard Jewell (plaintiff) worked as a security guard in Centennial Olympic Park (the park). Jewell reported a suspicious package at about the same time a 911 call warned about a bomb. Before the bomb exploded, Jewell helped evacuate the tower where the package was located. The media portrayed Jewell as a hero. Jewell permitted a photo shoot and 10 interviews. During interviews, Jewell said he had matched a man in the park to a composite sketch and the training of security and law enforcement personnel had been sufficient to handle the situation. Jewell encouraged the public to continue coming to the park. Four days after the bombing, the Atlanta Journal-Constitution (the journal) (defendant) published an article stating that the Federal Bureau of Investigation suspected Jewell of planting the bomb. Subsequent articles described Jewell as guilty and as having a motive for the bombing and an aberrant personality. Jewell was ultimately cleared as a suspect. Jewell sued the journal for defamation and sought a ruling that he was a private rather than public figure. The court ruled that Jewell’s public appearances made him a voluntary limited-purpose public figure and he therefore had to prove the journal acted with actual malice. Jewell appealed.
Rule of Law
Holding and Reasoning (Johnson, J.)
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