Bowman v. Heller

(dissenting, with whom Lynch, J., joins). I disagree with the court’s holding that the plaintiff was not a limited purpose public figure because the union election was not a public controversy. I conclude that the plaintiff became a limited purpose public figure when she voluntarily thrust herself into the election campaign. I also conclude that the caricatures at issue addressed the plaintiff’s campaign for the presidency, despite their horrid content. As a result, I would use the “actual malice” standard of liability in determining whether the plaintiff should recover on her claim of…