Defamation-Limited Purpose Public Figures

WI Court of Appeals – District I

Case Name: Tri-Corp Housing, Inc. v. Robert Bauman

Case No.: 2022AP000993

Officials: White, C.J., Donald, P.J., and Geenen, J.

Focus: Defamation-Limited Purpose Public Figures

Tri-Corp sued Milwaukee Alderman Robert Bauman for defamation and tortious interference with a contract, claiming that Bauman made defamatory statements about Tri-Corp’s operation of the West Samaria housing facility for cognitively disabled individuals. The jury found some of Bauman’s statements false and made with reckless disregard for the truth. However, the circuit court changed the jury’s answers, ruling there was no evidence of actual malice, which is required for defamation claims against public figures, and dismissed Tri-Corp’s claims. The court determined that Tri-Corp was a “limited purpose public figure” due to its involvement in a public controversy over West Samaria’s operations, requiring proof of actual malice. Additionally, the court concluded Bauman’s statements were matters of public concern, protected by the First Amendment.

Affirmed.

Decided 08/27/24

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