a school board director;
a candidate for judge;
a celebrity with access to the media; and
a union official.
Some examples of individuals deemed to be limited-purpose public figures by Pennsylvania courts include:
a locally renowned, Philadelphia-based singer who posed for as a centerfold and was extensively interviewed in an accompanying article in Playboy magazine;
a licensed architect and civil engineer who participated in numerous public building projects that had been the subject of public controversy; and
the president of an art foundation at the time the foundation's paintings went on a widely publicized international art exhibition tour.
Some examples of individuals deemed to be private figures by Pennsylvania courts include:
a person who allegedly misrepresented himself as a member of the board of a non-profit organization;
a dentist who received public reimbursement from state funds for dental work performed on lower-income patients; and
an individual planning to host of a private party when a neighbor called a newspaper to complain about the party.
Actual Malice and Negligence
In Pennsylvania, a private figure plaintiff bringing a defamation lawsuit must prove that the defendant was at least negligent with respect to the truth or falsity of the allegedly defamatory statements. Public officials, all-purpose public figures, and limited-purpose public figures must prove that the defendant acted with actual malice, i.e., knowing that the statements were false or recklessly disregarding their falsity. See the general page on actual malice and negligence for details on these standards.
Privileges and Defenses
Pennsylvania courts recognize a number of privileges and defenses in the context of defamation actions, including substantial truth, the opinion and fair comment privileges, and the fair report privilege.