The U.S. Supreme Court case Wolston v. Reader's Digest Association, Inc., et al., revolved around the issue of defamation and public figures. Ilya Wolston had been inaccurately identified by Reader's Digest as a Soviet spy in an article published in 1974, when he was actually only briefly under investigation for perjury related to his aunt and uncle who were convicted spies during the 1950s. He sued for libel but lost both at trial court level and on appeal because he was deemed a "public figure," which requires proving actual malice (knowledge that statements are false or reckless disregard for truth) to win a defamation suit under New York Times Co. v Sullivan precedent. However, the Supreme Court reversed these decisions in favor of Wolston, ruling that being involuntarily thrust into controversy does not automatically make one a public figure subject to higher standards of proof in libel cases; rather it is those who have assumed roles with significant societal influence or voluntarily injected themselves into public controversies who should be classified as such.

In the dissenting opinion for Wolston v. Reader's Digest Association, Inc., Justice William Rehnquist argued that the majority had incorrectly applied defamation law standards to a private individual who had become involved in public controversy. He contended that Ilya Wolston was not merely a private figure but rather became an involuntary public figure when he failed to respond to a grand jury subpoena during investigations into Soviet espionage activities in the U.S. As such, according to Rehnquist, Wolston should be subject to higher standards of proof regarding defamation claims as established by previous court rulings on public figures and officials. The justice also expressed concern about potential chilling effects on free speech if media outlets were held liable for minor inaccuracies while reporting on matters of significant public interest.