Individuals who are considered to be limited-purpose public figures remain so as long as the public has an "independent" interest in the underlying controversy. Unlike all-purpose public figures, it is relatively easy for a limited-purpose public figure to lose his status if the controversy in which he is involved has been largely forgotten. But most will still maintain their status. For example, a woman who had publicly dated Elvis Presley over a decade earlier, but who had since married and returned to "private" life, was found to remain a public figure for stories related to her relationship with Presley. See Brewer v. Memphis Publishing Co., 626 F.2d. 1238 (5th Cir. 1980).
Evaluating Public Officials, Public Figures, and Limited-Purpose Public Figures
A public official is a person who holds a position of authority in the government and would be of interest to the public even if the controversy in question had not occurred.
The actual malice standard extends to statements touching on virtually any aspect of the public official's life.
Even after passage of time or leaving office, public officials must still meet the actual malice standard because the public has a continued interest in the misdeeds of its leaders.
All-purpose public figures are those whose fame reaches widely and pervasively throughout society.
The actual malice standard extends to statements involving virtually any aspect of their private lives.
Passage of time does not affect their status as public figures as long as the source of their fame is of continued interest to the public.
A limited-purpose public figure is either:
One who voluntarily becomes a key figure in a particular controversy, or
One who has gained prominence in a particular, limited field, but whose celebrity has not reached an all-encompassing level.