Although Steven Hatfill obtained a $5.8 million settlement from the federal government after the Justice Department named him a “person of interest” in the 2001 anthrax attacks, his hopes of obtaining a libel judgment against the New York Times were dealt a blow when the 4th U.S. Circuit Court of Appeals affirmed a federal district court’s summary judgment in favor of the newspaper. Hatfill v. New York Times Co., No. 07-1162.

By holding that Hatfill was a “limited purpose public figure” for purposes of his libel suit against the Times — requiring Hatfill to demonstrate “actual malice” in the paper’s coverage — the 4th Circuit decided the case on July 14 in a manner that free speech advocates have favored, but that attorneys representing defamation plaintiffs have criticized as overly broad.