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Wells v. Liddy

U.S. Court of Appeals, Fourth Circuit
186 F.3d 505 (1999)


Facts

The conventional theory behind the Watergate break-in at the Democratic National Committee (DNC) headquarters in 1972 was that the burglars were trying to replace a listening device that had been installed during a previous break-in. Wells (plaintiff) worked as a secretary for a DNC officer whose phone was tapped. The burglars had a key to Wells’s desk in their possession when they were arrested. Liddy (defendant), then counsel to the Committee to Reelect the President, was convicted as a result of the break-in. A 1984 book, Secret Agenda, and the 1991 book Silent Coup alleged that the break-in was intended to learn whether the DNC was organizing prostitution for visitors. Silent Coup alleged that evidence of these activities was locked in Wells’s desk. Liddy repeated these allegations in various speeches, radio appearances, and on web sites. The trial court granted summary judgment for Liddy on all of his statements, finding that Wells, as an involuntary public figure, could not support a claim for defamation absent a showing that the statements were made with actual malice. Wells appealed.

Rule of Law

Issue

Holding and Reasoning (Williams, J.)

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