A rule that compels a government critic to ensure that all facts are true would result in self-censorship. Injury to official reputation doesn't give government the right to suppress. Plaintiffs who have assumed special prominence in the resolution of public issues or the character of public events. They are household names. Can be voluntary or involuntary, although it's mostly voluntary.
Usual example is a mob leader.
They are considered public figures only if the defamation was related to that public context. In all other cases, person is private. In a 5-4 decision, the SC held that Gertz was a private figure and that as a private figure he is in greater need of protection from defamation than public figures who enjoy greater media access with which to counteract false accusations. So, case tells us that the court will look at every specific controversy to make a decision and just because a private person is swept up into a public issue, that person does not automatically become a public person.