Craig Sparks, a resident of the City of Montezuma, Georgia, brought this action for defamation and tortious interference with employment against the City Manager, David Peaster. After discovery, the trial court carefully analyzed Sparks’s claims and entered a lengthy, meticulous and thoughtful order granting summary judgment in favor of Peaster. We agree with the trial court that Sparks, a local political activist, is a limited-purpose public figure by reason of his extensive participation in city affairs and that Sparks failed to show that Peaster acted with actual malice.1 We therefore affirm. The facts of this case were largely developed from pleadings and discovery in a federal district court action brought by Sparks under 28 USC § 1983. The district court granted summary judgment against Sparks on his federal claims and declined to exercise pendent jurisdiction over the remaining state claims. Sparks promptly filed this action asserting his state law claims for defamation and tortious interference with employment. The trial court here adopted and incorporated the discovery and pleadings from the federal action.
The record shows that this litigation arose out of persistent difficulties between Sparks and city government officials. The controversy ultimately widened to involve the mayor and city council, the police chief and assistant chief, employees of the city clerk’s office, and a local newspaper as well as Peaster. The two matters of which Sparks complains here are a conversation between Peaster and the interim editor of the newspaper and a letter Peaster wrote to Sparks’s employer, Weyerhauser. According to the editor, Peaster told her that Sparks has a “serious cocaine habit” and that “his brains are just fried with drugs.”2 The letter was in reference to a city recognition of Weyerhauser for its charitable contributions to Macon County. Peaster apologized to the community relations manager for Weyerhauser that the ceremony did not receive much recognition in a local newspaper, because it was “upstaged by ‘Robert’s Rules of Order’ and coverage of a citizen who gives nothing back to the community but has a reputation as a problem maker and not a problem solver.”
