## Facts

- Lt. Carey Dunai Lohrenz, a U.S. Navy F–14 pilot, became one of the first two women to qualify as combat pilots in the Navy amid a prominent public controversy over women in combat roles.
- Lohrenz pursued F–14 combat aviation while aware of the controversy and the attention likely to follow from being a pioneering participant.
- After the other female F–14 pilot died in a training accident in October 1994, public attention to women combat pilots increased.
- Elaine Donnelly and the Center for Military Readiness (CMR), public opponents of women in combat roles, issued publications (including a report and press materials) criticizing the Navy’s integration of women into combat aviation.
- The publications asserted that Lohrenz had been rushed through training, received special treatment, and posed safety risks; they questioned her qualifications and competence as a combat pilot.
- Lohrenz later lost flight status under contested circumstances and alleged that the publications caused reputational harm and contributed to damage in her naval career.
- Lohrenz sued Donnelly and CMR for defamation; the district court granted summary judgment for defendants, finding Lohrenz a limited-purpose public figure and finding insufficient evidence of actual malice.

## Issues

1. Whether Lohrenz was a voluntary limited-purpose public figure in the public controversy over women in combat aviation, requiring proof of actual malice for defamation liability.
2. Whether the summary judgment record could permit a reasonable jury to find, by clear and convincing evidence, that Donnelly and CMR acted with actual malice.
3. Whether the court needed to address limits on the involuntary limited-purpose public figure doctrine.

## Decision

- The D.C. Circuit affirmed summary judgment for Donnelly and CMR.
- The court held Lohrenz was a voluntary limited-purpose public figure regarding the controversy over women in combat aviation.
- The court held Lohrenz failed to produce evidence from which a reasonable jury could find actual malice by clear and convincing evidence.
- Because Lohrenz was deemed a voluntary public figure, the court did not reach her argument seeking to limit prior circuit precedent addressing involuntary limited-purpose public figures.

## Legal Principles

- A plaintiff is a limited-purpose public figure when (1) a public controversy exists, (2) the plaintiff plays a central role in that controversy by voluntary conduct, and (3) the alleged defamation is germane to the plaintiff’s role in the controversy.
- A person may become a limited-purpose public figure by knowingly assuming a highly visible role closely tied to an existing public controversy, even without actively seeking media exposure or attempting to influence public opinion.
- For public-figure defamation claims, the plaintiff must prove actual malice: publication with knowledge of falsity or reckless disregard for truth.
- At summary judgment, the plaintiff must present evidence sufficient for a reasonable jury to find actual malice by clear and convincing evidence; disputes over interpretation, harsh criticism, or ideological bias do not alone establish actual malice absent proof of subjective serious doubt or purposeful avoidance of the truth.

## Conclusion

The court treated a pioneering Navy F–14 combat pilot as a voluntary limited-purpose public figure in the public debate over women in combat aviation and affirmed summary judgment for advocacy defendants because the record did not support a clear-and-convincing finding that the challenged statements were made with actual malice.


Lohrenz v. Donnelly, 350 F.3d 1272 (D.C. Cir. 2003)