Fourth Circuit: Angela Horne v. WTVR, LLC

Finance Director of local school board was appropriately considered a public official for the purposes of a defamation action, as the position invites public scrutiny; categorically, a past felony conviction is relevant in such a case.

News organization's forgoing a lead that the plaintiff had been knowingly hired by the board did not suffice for actual malice, as the allegation was the sort of thing that might be said if the applicant had in fact lied on the application. 

Common-law reporter's privilege prevails over speculative assertion that the identity of the source might reveal the actual malice.

http://www.ca4.uscourts.gov/opinions/171483.P.pdf