## Facts

- In 1957–1958, a federal grand jury in New York investigated Soviet espionage activities; Wolston’s aunt and uncle were arrested and later pled guilty to espionage.
- Wolston, living in Washington, D.C., received grand jury subpoenas and failed to appear for one; he had sought relief from travel due to a mental condition.
- A federal judge initiated contempt proceedings; Wolston appeared and offered to testify, but the offer was refused.
- Wolston pled guilty to criminal contempt and received a suspended sentence after his wife was called to testify about his mental condition.
- Local press reported the contempt episode, but publicity quickly ended, and Wolston largely returned to private life.
- In 1974, publishers released a nonfiction book describing Soviet espionage that identified Wolston as a Soviet agent and referenced his contempt conviction in connection with espionage indictments.
- Wolston sued the author and publishers for libel, alleging the statements were false and defamatory.

## Issues

1. Whether Wolston was a “public figure” for defamation purposes because of prior publicity surrounding his contempt conviction related to an espionage investigation.
2. If not a public figure, whether applying the “actual malice” requirement as a condition of recovery was erroneous.

## Decision

- The Supreme Court reversed the judgment for defendants.
- The Court held Wolston was not a public figure, including not a limited-purpose public figure regarding Soviet espionage.
- Because Wolston was a private individual, he was not constitutionally required to prove actual malice to recover for libel.
- The case was remanded for further proceedings under the proper standard applicable to private plaintiffs.

## Legal Principles

- Public-figure status generally requires voluntary conduct, such as assuming a role of special prominence or thrusting oneself into a public controversy to influence its resolution.
- A person is not transformed into a public figure merely by becoming involved in, or associated with, a matter that attracts public attention.
- Brief, involuntary notoriety does not create continuing public-figure status years later absent subsequent voluntary engagement in public controversy.
- Private individuals, lacking comparable access to channels of rebuttal and not having assumed heightened public scrutiny, receive greater protection than public figures under defamation law.

## Conclusion

Wolston’s contempt conviction and temporary publicity arising from a grand jury investigation did not make him a public figure because he did not voluntarily seek public attention or attempt to influence any public controversy; therefore, he could pursue his libel claim without meeting the actual-malice standard.


Wolston v. Reader’s Digest Ass’n, Inc., 443 U.S. 157 (1979)