Clawson v. Longview Publishing Co.
589 P.2d 1223 · Washington Supreme Court · 1979
Facts
A newspaper published an article alleging that Eugene Clawson, Administrator of the Cowlitz County Motor Pool, used county funds and time to repair the sheriff's son's car. Clawson sued the publishing company and its editor for defamation, and the trial court found for Clawson under a negligence standard. The newspaper appealed, arguing Clawson was a public official.
Issue
Was Eugene Clawson, the Administrator of the Cowlitz County Motor Pool, a 'public official' for purposes of defamation law, thereby requiring him to prove 'actual malice' to recover damages?
Holding
Yes, the court held that Eugene Clawson was a 'public official' as a matter of law, requiring him to prove 'actual malice' for defamation. The trial court's judgment was reversed, and the case was remanded for further proceedings under the 'actual malice' standard.
Rule
An individual is a 'public official' for defamation purposes if their position has apparent importance, inviting public scrutiny and discussion, and if the defamatory material bears closely upon their fitness for office. This includes public employees who exercise unsupervised discretion in the expenditure of public funds, especially when potential conflicts arise from private business activities, necessitating proof of 'actual malice' (knowledge of falsity or reckless disregard for truth) for defamation claims.
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