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Bandelin v. Pietsch
Idaho Supreme Court
563 P.2d 395 (1977)
Glenn Bandelin (plaintiff) was a leading attorney and former state legislator who was prominent in local politics and the community. Bandelin practiced law, but his public role had diminished. Bandelin was appointed guardian of a woman who subsequently died. Bandelin waited nearly 15 months to initiate final-accounting proceedings. The court found Bandelin negligent and ordered the county prosecutor to institute contempt proceedings. Morgan Monroe was a reporter for the Sandpoint News Bulletin (Sandpoint), a weekly newspaper published by L.E. Pietsch (defendants). Monroe’s articles, tracking developments in what Monroe called a “puzzling” case that had “shaken” the county’s legal community, were published in 11 Sandpoint editions. Bandelin sued Sandpoint, Pietsch, and Monroe for libel, claiming that two articles falsely stated he had been adjudged in contempt when the case had not yet been tried. The court granted Sandpoint’s motion for summary judgment. Bandelin appealed, arguing he was not a public figure, and even if he were, the evidence established actual malice.
Rule of Law
Holding and Reasoning (Donaldson, J.)
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