Public figures:  have no governmental capacities
(i)    All purpose public figures:  who b/c of reputation, wealth, etc. is for all intent and purposes a public figure (ex-presidents, jfk jr.) ? public for all facets of life
(ii)    Limited public figures:  voluntarily cast themselves into the vortex of public discussion for specific issue ? for the purposes of that specific issue, they are public figures.
1.    going to court is not a choice, so not thrusting self into vortex of public opinion Time v. Firestone (adultery case)
2.    you can’t make the person a public figure through the defamation itself  Hepps