an assistant regional administrator of a branch office of the United States Securities and Exchange Commission; and
a court-appointed child psychologist in a child custody case who had the authority to determine visitation rights.
Some examples of individuals deemed to be limited-purpose public figures by Texas courts include:
a candidate for city counsel, because he thrust himself into the middle of a public controversy;
a former special counsel for a court of inquiry investigating alleged irregularities in county fund management;
a zoologist who actively participated in a controversy involving his work with kinkajous by appearing on television, giving interviews to magazines, and orchestrating a letter-writing campaign;
a broadcast news reporter who hosted a segment that regularly appeared on television;
an abortion clinic protester who regularly appeared on a public street near the entrance to the clinic;
a group of hackers called Legion of Doom who sought publicity in a controversy over computer security.
Actual Malice and Negligence
In Texas, 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 statement. 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 statement was false or recklessly disregarding its falsity. See the general page on actual malice and negligence for details on these standards.
Privileges and Defenses