a.    Powell, writing for the majority, set out the test for when
speech involves a matter of private concern:  When a private citizen
sues concerning statements that do not involve an issue of public
interest, he can recover presumed and punitive damages without a
showing that the defendant actual malice—that D recklessly
disregarded the truth or knew of the falsity of his statement.
b.    Powell applied the Gertz balancing test in arriving at the
above rule: the free speech interests of D had to be balanced against
the competing legitimate state interests in compensating individuals
for the harm they suffer from defamatory falsehood.  Speech on
matters of purely private concern is of less First Am. value than
speech of public concern (which is at the “heart of the First Am.’s
protection”).  An individual has a strong interest in being
compensated if he suffers from such speech of public concern.
c.    How does one determine if speech involves public concern?
Powell in the majority says the court should focus on the “context,
form, and content” of the speech.