<b>Decision of Note:</b> Rapper Isn't Public Figure

The Court of Appeals of Georgia, Fourth Division, found that a local rap artist wasn't a public figure for purposes of a defamation suit over comments made about him on a local radio station. Riddle v. Golden Isle Broadcasting, A05A1436.

Travis Riddle filed suit after a listener phoned WSEG-FM in Brunswick, GA, and wondered on air whether Riddle had murdered his girlfriend, who in fact was alive. The trial court granted summary judgment for Golden Isle on the ground that Riddle was a public figure, under the state's OCGA Sec. 51-5-10(a), who would then need to prove actual malice, rather than ordinary negligence, by the broadcaster, which the trial court concluded had acted with due care.

Reversing, the Court of Appeals noted: “While Riddle may have enjoyed some popularity among Brunswick, Georgia rap music fans, he was not a household name. Golden Isles' own station managers had not heard of him. Riddle had produced little income from his performances and was very early in the process of seeking investors. The appellate record contains only one local newspaper article, a brief feature about Riddle's music. At the time of the alleged defamation, Riddle was living in Atlanta and working as a banquet server. While Riddle may have been gaining some popularity in local music circles, the evidence does not demonstrate that he had achieved the degree of celebrity and influence typical of a general purpose public figure.”

Finding Riddle also wasn't a limited purpose public figure, the court of appeals concluded: “There is no evidence in the record that Riddle was named a suspect in a murder investigation. In fact, there was no murder. Riddle became the subject of local gossip and speculation based upon the temporary disappearance of his ex-girlfriend. While [the ex-girlfriend's] disappearance might have been newsworthy, there [was] no evidence that it was actually publicized in the media. Further, while the resolution of [her] disappearance might have affected [her] friends and family and the local law enforcement personnel who directly participated in that matter, it had no ramifications for the general public.”

The Court of Appeals of Georgia, Fourth Division, found that a local rap artist wasn't a public figure for purposes of a defamation suit over comments made about him on a local radio station. Riddle v. Golden Isle Broadcasting, A05A1436.

Travis Riddle filed suit after a listener phoned WSEG-FM in Brunswick, GA, and wondered on air whether Riddle had murdered his girlfriend, who in fact was alive. The trial court granted summary judgment for Golden Isle on the ground that Riddle was a public figure, under the state's OCGA Sec. 51-5-10(a), who would then need to prove actual malice, rather than ordinary negligence, by the broadcaster, which the trial court concluded had acted with due care.

Reversing, the Court of Appeals noted: “While Riddle may have enjoyed some popularity among Brunswick, Georgia rap music fans, he was not a household name. Golden Isles' own station managers had not heard of him. Riddle had produced little income from his performances and was very early in the process of seeking investors. The appellate record contains only one local newspaper article, a brief feature about Riddle's music. At the time of the alleged defamation, Riddle was living in Atlanta and working as a banquet server. While Riddle may have been gaining some popularity in local music circles, the evidence does not demonstrate that he had achieved the degree of celebrity and influence typical of a general purpose public figure.”

Finding Riddle also wasn't a limited purpose public figure, the court of appeals concluded: “There is no evidence in the record that Riddle was named a suspect in a murder investigation. In fact, there was no murder. Riddle became the subject of local gossip and speculation based upon the temporary disappearance of his ex-girlfriend. While [the ex-girlfriend's] disappearance might have been newsworthy, there [was] no evidence that it was actually publicized in the media. Further, while the resolution of [her] disappearance might have affected [her] friends and family and the local law enforcement personnel who directly participated in that matter, it had no ramifications for the general public.”