Sparks v. Peaster

Smith, Chief Judge.

Craig Sparks, a resident of the City of Montezuma, brought this action for defamation and tortious interference with employment against the city manager, David Peaster. After discovery, the trial court carefully analyzed Sparks’s claims and entered a lengthy, meticulous, and thoughtful order granting summary judgment in favor of Peaster. We agree with the trial court that Sparks, a local political activist, is a limited purpose public figure by reason of his extensive participation in city affairs and that Sparks failed to show that Peaster acted with actual malice. We…