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Lohrenz v. Donnelly

United States Court of Appeals for the District of Columbia Circuit
350 F.3d 1272 (2003)


Facts

In August 1994, the United States Navy assigned Carey Lohrenz (plaintiff) a position as an F-14 jet pilot. At the time, there was a public controversy over the appropriateness of women in combat roles. Lohrenz was aware of the controversy when she chose her career path, as well as of the likelihood that her role as one of two female combat pilots would place her at the center of the controversy. In October 1994, the other female pilot died during a training exercise, and the controversy surrounding female combat pilots intensified. Elaine Donnelly (defendant) had been campaigning against allowing women to assume combat roles. After the crash, Donnelly began targeting Lohrenz, specifically questioning her competence as a pilot. After losing her position as a pilot, Lohrenz filed a defamation action against Donnelly, claiming that Donnelly’s defamatory publications had caused Lohrenz to lose her pilot position. The district court granted Donnelly’s motion for summary judgment, finding that Lohrenz was a limited-purpose public figure and had failed to show actual malice. Lohrenz appealed the decision.

Rule of Law

Issue

Holding and Reasoning (Rogers, J.)

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