Patrick Clawson was described by reporter Karen Branch-Brioso in a newspaper story as a “1970s era St. Louis journalist turned private eye turned FBI informant.” The story was published in the St. Louis Post-Dispatch. The fact that he had been characterized as an “informant” bothered Clawson, who saw it as damaging to his reputation.

Accordingly, he brought a libel case against the Post-Dispatch. Recall that to be libelous, a statement must be false and “hold the victim up to ridicule, contempt, or hatred.” Clawson would have preferred the term “whistleblower” rather than “informant,” because that term commands more respect. Why is the use of the term “informant” to describe Clawson not libelous? Explain. Clawson v. St. Louis Post-Dispatch, No. 04-CV-486; see also “Media Law: Label of ‘Informer’ Is Found Not Defamatory,” The National Law Journal, September 11, 2006.