## Facts

- Richard Jewell worked as a security guard at Centennial Olympic Park during the 1996 Atlanta Olympics when a bomb exploded.
- Early media reports portrayed Jewell as a hero for identifying a suspicious package and assisting evacuation efforts.
- After the FBI investigated Jewell as a suspect, media coverage shifted and AJC articles—citing unnamed law-enforcement sources—reported that the FBI suspected Jewell and discussed motive and character.
- Jewell was later cleared of involvement and sued the AJC and related defendants for defamation, alleging the articles falsely portrayed him as the bomber.
- In discovery, Jewell sought the reporters’ confidential sources; the trial court compelled disclosure and, after refusal, held two reporters in contempt and ordered indefinite incarceration until they complied.
- The trial court also ruled Jewell was a limited-purpose public figure regarding the bombing controversy and denied the AJC’s motion for judgment on the pleadings and motion for summary judgment.

## Issues

1. Whether the trial court erred by compelling disclosure of confidential sources and holding reporters in contempt without applying a proper qualified-privilege analysis.
2. Whether Jewell was a limited-purpose public figure concerning the public controversy surrounding the Olympic Park bombing and investigation.
3. Whether the AJC was entitled to judgment on the pleadings or summary judgment on Jewell’s defamation claims.

## Decision

- The court reversed the contempt order and the disclosure ruling as applied, holding the trial court used an incorrect categorical approach and failed to conduct the required balancing before compelling source disclosure.
- The court affirmed the determination that Jewell was a limited-purpose public figure, concluding he was at least involuntarily drawn into the controversy and also voluntarily participated in aspects of it through interviews and public statements.
- The court affirmed denial of judgment on the pleadings and summary judgment because factual disputes remained, and discovery relevant to actual malice had not been fully developed.

## Legal Principles

- Reporters in civil defamation cases may assert a qualified protection for confidential sources; courts must apply a case-specific balancing test rather than a categorical rule.
- In deciding whether to compel disclosure, courts should weigh the relevance and importance of the information, whether it is available from alternative sources, and the public interest in protecting newsgathering and confidential sources.
- A person can be a limited-purpose public figure when thrust into a public controversy, and voluntary media engagement about the controversy may further support limited-purpose public-figure status.
- A limited-purpose public figure must prove actual malice—knowledge of falsity or reckless disregard for truth—to recover for defamation.

## Conclusion

The court required a balancing analysis before ordering disclosure of reporters’ confidential sources and reversed contempt sanctions imposed without that analysis, while affirming that Jewell was a limited-purpose public figure and allowing his defamation case to proceed under the actual-malice standard.


Atlanta Journal-Constitution v. Jewell, 555 S.E.2d 175 (Ga. Ct. App. 2001)