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3845 REVIEW DENIED A person who has written a book about committed same-sex relationships and child adoption by same sex couples, and who has appeared on many television programs and otherwise made her views known to the general public, is a limited issue public figure, required to show actual malice in a defamation action; because the verb "convict" is commonly misused to refer to proof of anything blameworthy, a layperson's use of the phrase "convicted perpetrator of domestic violence" in reference to a person found by the Family Court to have engaged in domestic violence was not necessarily false and was not spoken with knowledge of falsity or sufficiently reckless disregard of the truth to justify the conclusion that the speaker was activated by actual malice.CitationANNETTE F v SHARON S (Lesbian Adoption) 119 CA4 1146 [See: CCP 425.16; Gertz v Robert Welch 418 US 323; Reader's Digest v Superior Court 37 C3 244]
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