The Involuntary Public Figure Class of Gertz v. Robert Welch: Dead or Merely Dormant?
This article does not resolve the debate over involuntary public figures but argues instead that in light of the Court’s pronouncements in Firestone, Hutchinson and Walston, ·the involuntary class should be abolished. Part I briefly traces the evolution and significance of public figure status in defamation law, and reviews various interpretations of the involuntary public figure references in Gertz. Part II examines the status of the involuntary class after Firestone, Hutchinson and Walston, and discusses the extent to which future use of the class remains logically consistent with those decisions. Finally, the article considers the merits of such a category in defamation law, concluding that the class of involuntary public figures serves no useful purpose and should be abandoned.