Since the "New York Times Co. v. Sullivan" decision in 1964, courts have debated the degrees of protection from defamation that should be offered to individuals and the concomitant degree of freedom that the press should have to report on matters of public concern. Most recently, the Supreme Court has attempted to balance these competing interests in the cases of "Gertz v. Robert Welch, Inc." and "Time, Inc. v. Firestone." From these two cases come new definitions of public figures and private individuals, two categories given differing amounts of protection under the law. After examining the various manners in which state courts and lower federal courts have construed these definitions, it is concluded that there will be no rest for publishers and broadcasters while the criteria for determining who is a public figure and who is a private individual are so unsettled. (Author/KS)