Hutchinson v. Proxmire

In Hutchinson v. Proxmire (1979) 443 U.S. 111, a scientist who engaged in federally funded research received the "Golden Fleece Of The Month" award bestowed by a United States Senator. In rejecting a contention that Hutchinson was a limited purpose public figure, the court said at page 135 61 L.Ed.2d at page 431: "Hutchinson did not thrust himself or his views into public controversy to influence others. Respondents have not identified such a particular controversy; at most, they point to concern about general public expenditures. But that concern is shared by most and relates to most public expenditures; it is not sufficient to make Hutchinson a public figure. If it were, everyone who received or benefited from the myriad public grants for research could be classified as a public figure -- a conclusion that our previous opinions have rejected. The 'use of such subject-matter classifications to determine the extent of constitutional protection afforded defamatory falsehoods may too often result in an improper balance between the competing interests in this area." The Court held that plaintiff there, a prominent scientist and administrator who had broad "access to the media," was likewise not a public figure because: "Hutchinson did not thrust himself or his views into public controversy to influence others. Respondents have not identified such a particular controversy; at most, they point to concern about general public expenditures." ( Id. at p. 135.)