Waldbaum v. Fairchild Publications, Inc.

627 F.2d 1287 (1980)

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Waldbaum v. Fairchild Publications, Inc.

United States Court of Appeals for the District of Columbia Circuit
627 F.2d 1287 (1980)

  • Written by Lauren Petersen, JD

Facts

Eric Waldbaum (plaintiff) was the chief executive officer of Greenbelt Consumer Services, Inc. (Greenbelt), a food cooperative. Waldbaum pushed for innovative practices in the supermarket industry, and he and Greenbelt were featured in trade journals and by the general media. After five years at Greenbelt, Greenbelt’s board ousted Waldbaum. A supermarket trade publication covered the ouster. It described Greenbelt as having been losing money during the prior year and retrenching. Waldbaum sued the publication’s owner, Fairchild Publications, Inc. (Fairchild) (defendant) for libel. Waldbaum alleged that the article characterized him as a poor businessman by falsely reporting that Greenbelt had been losing money and retrenching. Fairchild moved for summary judgment. Fairchild argued that because Waldbaum was a public figure, he could only recover for defamation if Fairchild had published misstatements in actual malice. Waldbaum argued that he was not a public figure, and consequently the standard for libel was negligence. Additionally, Waldbaum conceded that Fairchild had not acted with actual malice. The trial court granted Fairchild’s motion for summary judgment. Waldbaum appealed.

Rule of Law

Issue

Holding and Reasoning (Tamm, J.)

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