Linda Erickson, Appellant v. Jones Street Publishers, LLC, Respondent

Summary

The court held that Erickson, a private guardian ad litem, was a private-figure plaintiff rather than a public official or limited-purpose public figure, and therefore reversed the directed verdict on her defamation claim. It found sufficient evidence to support the jury's constitutional-actual-malice finding and held that the newspaper waived objections to the agreed bifurcation procedure, requiring reinstatement of the liability verdict and a remand for actual and punitive damages. The court otherwise affirmed dismissal of the invasion-of-privacy and negligence claims and upheld the ruling that the article's sexual-relationship statement did not refer to Erickson. Justice Pleicones, concurring in part and dissenting in part, would have remanded for a new trial on liability and damages because he found no jury verdict to reinstate.