claim because it is opinion, or because it is a true statement of fact, or because it was false but made without actual malice, may not serve as the basis for an IIED claim brought by a public figure. Falwell by its terms governs only public figure cases. Because I believe that the state's interest in protecting private individuals from the intentional infliction of emotional distress outweighs the First Amendment interest in speech on private matters concerning private individuals, I would decline to extend Falwell to IIED claims brought by private figures such as Carpenter. The state has a "strong and legitimate" interest in protecting private individuals from unprovoked verbal attacks. Private figures like Carpenter are both less equipped to defend themselves against attac 8) (<HOLDING>). 14 . Despite the error of concluding that
recognizing absolute immunity for attorneys and board members of the texas medical board holding that a candidate for a planned unit development associations board was a limited purpose public figure because as a candidate for election to the associations board of directors plaintiff thrust himself into a spotlight which justified viewing him as a public figure for the limited purpose of his candidacy holding that candidate for state medical board voluntarily placed herself in position of public attention given strong public interest in board appointees qualifications recognizing that public utilities affect the public interest in that they render essential public services to a large number of the general public holding that board panels may consider only independent medical evidence to support their findings resulting in va altering its longstanding practice of including members of the board with medical expertise on each panel and relying on their medical opinion in rendering board decisions