Faxon v Michigan Republican State Central Committee: Landmark Case Which Defines Standard for Defamation of a Public Figure

244 Mich App 468: This landmark decision helps establish the necessary showing of actual malice that applies when a plaintiff in a defamation action is a public official or public figure. In this case, a former state senator unsuccessfully sued a political party for defamation based on a brochure, distributed during the senator's re-election campaign, which asserted that the senator had sold a fake antique vase to an art collector and had claimed that the art collector could not sue him because of legislative immunity. This case established that the failure to investigate the allegations in newspaper reports before including them in a political brochure does not constitute the reckless disregard that underlies actual malice.