Quimbee logo
DMCA.com Protection Status
From our private database of 19,800+ case briefs...

Waldbaum v. Fairchild Publications, Inc.

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


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


Holding and Reasoning (Tamm, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 509,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 509,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 19,800 briefs, keyed to 985 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial