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Gray v. St. Martin’s Press, Inc.

United States District Court for the District of New Hampshire
1999 WL 813909


Facts

Robert Gray (plaintiff) filed a defamation suit against St. Martin’s Press, Inc. (St. Martin’s) (defendant), publisher of a book authored by Susan Trento (defendant) called The Power House, Robert Keith Gray and the Selling of Access and Influence in Washington (the Book). The Book discussed in several areas how members of lobbying and public relations firms influenced federal government operations and focused on Gray as being one of the most well-connected men in those circles and one of the most powerful men in Washington, D.C. The defendants filed a motion for summary judgment claiming that Gray was a public figure and therefore was required to demonstrate that defendants had acted with “actual malice” in order to prevail on his defamation claims. In support of their motion, defendants showed that not only was Gray well known around the Washington, D.C., political networks, but also was the subject of a television documentary and several hundred newspaper and magazine articles.

Rule of Law

Issue

Holding and Reasoning (McAuliffe, J.)

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