Victoria v. Le BLANC

Plaintiff appeals from a summary judgment that dismissed her defamation claim against defendant. The claim is based on statements that defendant made in two letters that he wrote to a local newspaper. We conclude that in those letters defendant criticized plaintiffs conduct as a public official and that federal law therefore requires plaintiff to prove a higher level of culpability than for defaming a private citizen. We also hold that the evidence on summary judgment is sufficient to create a jury question of whether plaintiff satisfied that standard. We therefore reverse.

We state the facts…