California Court: A Court-appointed Conservator is a 'Public Official' for Defamation Analysis

In a broadcast report concerning Plaintiff (P), CBS dramatized reports about P's conduct acting as court-appointed conservator of an elderly woman. When P sued CBS for defamation, CBS defended on Anti-SLAPP grounds. California Court of Appeals for the Third District held that Anti-SLAPP did not apply because: (1) as a Court-appointed conservator P is a “public official”, and (2) as a public official, P had to prove that CBS published defamatory statements about her with “actual malice” which P has not done. Judgment reversed.