## Facts

- Ida Maxwell “Maxie” Wells briefly worked as a secretary at the Democratic National Committee (DNC) in 1972.
- After the June 17, 1972 Watergate break-in, burglars were found with a key to Wells’s desk.
- Years later, authors advanced an alternative “call-girl” theory asserting the break-in sought evidence of a prostitution operation allegedly connected to the DNC and supposedly stored in Wells’s desk.
- G. Gordon Liddy publicly advocated this theory, asserting the burglars sought materials in Wells’s desk, including a compromising photograph and other items allegedly used in connection with prostitution services.
- Liddy repeated these allegations in multiple public forums, including speeches, radio, and online postings.
- Wells denied any involvement in prostitution or related wrongdoing and alleged that Liddy’s statements defamed her and harmed her reputation.

## Issues

1. Whether Wells was a limited-purpose public figure or an involuntary public figure for purposes of the public controversy concerning Watergate, requiring proof of actual malice.
2. Whether the district court correctly applied Louisiana law to all defamation counts, including the applicable fault standard.

## Decision

- The Fourth Circuit reversed the district court’s grant of summary judgment for Liddy and remanded.
- The court held Wells was not a limited-purpose public figure because she did not voluntarily assume a prominent role in the Watergate controversy, lacked meaningful access to channels of effective communication, and did not seek to influence the controversy’s outcome.
- The court held Wells was not an involuntary public figure because her connection to Watergate was peripheral and did not make her a central or indispensable figure in the controversy.
- The court held Louisiana law did not govern two of Wells’s defamation counts, making the district court’s across-the-board choice-of-law ruling incorrect.
- Because Wells was a private figure and some counts were governed by other states’ laws, summary judgment based on a universal “actual malice” requirement could not stand.

## Legal Principles

- A limited-purpose public figure is one who voluntarily injects herself into a particular public controversy to influence its resolution; the defendant bears the burden to establish the required elements.
- Involuntary public-figure status is rare and requires that the plaintiff become a central figure in a public controversy through no purposeful action of her own.
- A person’s tangential association with a major public controversy does not, by itself, convert her into a public figure for defamation purposes.
- In multistate defamation, different publications or counts may be governed by different states’ laws; an erroneous choice-of-law ruling can improperly alter the applicable fault standard and defeat claims at summary judgment.
- At the summary judgment stage, when the plaintiff’s status and governing law are misclassified, disputed issues concerning falsity, defamatory meaning, fault, and damages generally must be resolved under the correct standards on remand.

## Conclusion

The Fourth Circuit held that Wells remained a private figure despite her incidental connection to Watergate and that the district court wrongly imposed an actual-malice burden through erroneous public-figure and choice-of-law determinations; it therefore reversed summary judgment and remanded for further proceedings under the proper governing law and fault standards.


Wells v. Liddy, 186 F.3d 505 (4th Cir. 1999)