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Riddle v. Golden Isle Broadcasting

A musician who achieved some notoriety among rap fans in his hometown was not a general purpose public figure.

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The Superior Court of Glynn County granted summary judgment to Golden Isles Broadcasting, LLC, “Golden Isles”, the company that owns the radio station Travis Riddle claims defamed him. Riddle appeals, contending the trial court erred in finding that he was a public figure, that the defamatory statement was made without actual malice, and that Golden Isles is shielded from liability under OCGA § 51-5-10. Because the trial court erred in concluding that Riddle was a public figure, and because material issues of fact remain for jury resolution, we must reverse. “On appeal from the grant of summary judgment this Court conducts a de novo review of the evidence to determine whether there is a genuine issue of material fact and whether the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law.” Citation omitted. Cox Enterprises, Inc. v. Nix , 274 Ga. 801, 804 2 560 SE2d 650 2002. So viewed, the record reveals the following relevant, undisputed facts.

Radio station WSEG “Hot” 104.1 of Brunswick, Georgia, employed Antonio “Tone” Warrick as a disc jockey for a rap music show that aired daily from 7:00 p.m. to 10:00 p.m. The show featured music, not news. The radio station’s broadcast range extends about 30 miles from its Brunswick tower. Warrick, who was acquainted with Travis Riddle and his family, played Riddle’s rap music occasionally, including Riddle’s recent hit “Daddy’s Little Boy.”

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