Wells v. Liddy

186 F.3d 505 (4th Cir. 1999)

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Nature of the Case

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Facts

D believed that the Watergate break-in was related to the theory that some members of the DNC were using a call girl ring as an asset to entertain visiting dignitaries. To that end, it was believed that they had a manila envelope that you could open or close by wrapping a string around a wafer. And in that envelope were twelve photographs of an assortment of the girls and then one group photograph of them. It was kept he said in that desk of Ida Maxine Wells (P). P, as well as others, made these statements numerous times in numerous venues.

By 1991, D had repeated the theories of various books that touted this theory at appearances at JMU, on a cruise ship, over his radio show, and on a web page. P sued D for defamation because of the implication that she too was a participant in the scheme to secure prostitutes. The trial judge granted summary judgment to D on all allegations. The court of appeals upheld two of the events (the JMU and cruise ship) but concluded that the radio show and the web page did not rise to defamatory status. The court then turned to the constitutional issues relating to the two surviving charges. The district court concluded on those charges that P was an involuntary public figure and had to prove actual malice before she recovers any compensatory damages for actual injuries. D contends that the court's conclusion was correct but that in the alternative P's participation in the Watergate-related dialogue was sufficient to qualify her as a voluntary limited purpose public figure.