Clyburn v. News World Communications, Inc.

903 F.2d 29, 284 U.S. App. D.C. 212 (1990)

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Clyburn v. News World Communications, Inc.

United States District Court for the District of Columbia Circuit
903 F.2d 29, 284 U.S. App. D.C. 212 (1990)

Facts

Joann Medina collapsed early in the morning during a party. John Clyburn (plaintiff) was one of the people with Medina at the time of her collapse. A party attendee called 911, and paramedics tried to revive Medina, but she fell into a coma and died four days later. Law enforcement, including the Drug Enforcement Administration, investigated the connection between Medina and the mayor and other high-ranking city officials to determine whether any drug dealing or drug use could be tied to them. Clyburn had a consulting firm and contracts and connections with many government officials. A series of articles in the Washington Times (the Times) (defendant) described Medina’s drug overdose and death in detail as well as the investigation into connections with public officials. The Times articles stated that Clyburn waited several hours before calling 911 to give other party attendees time to leave the party. Clyburn sued News World Communications, Inc. (defendant), publisher of the Times, for libel. The Times filed a motion to dismiss on the grounds that Clyburn was a public figure for the purpose of this case and therefore required to prove actual malice, but Clyburn had not introduced sufficient evidence of actual malice. The trial court granted the motion for summary judgment, and Clyburn appealed.

Rule of Law

Issue

Holding and Reasoning (Williams, J.)

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