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
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