The first issue tackled by the court was whether Khawar was a public figure. n127 At the time the article
and book were published, he was a farmer in Bakersfield, California. n128 Khawar never sought out media attention
any time between the assassination of Kennedy and the publication of the book and article. n129 Although a Bakersfield
TV station interviewed Khawar about the article, the court held that he did not seek out substantial media attention
sufficient to make him a voluntary public figure. n130 "If such access were sufficient to support a public figure
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19 Vill. Sports & Ent. L.J. 135, *156
characterization, any member of the media - any newspaper, magazine, television or radio network or local
station-could confer public figure status simply by publishing sensational defamatory statements against any private
individual." n131 As a result, the Supreme Court of California affirmed a lower court judgment upholding Khawar's
status as a private figure