appropriate to consider also whether the communication pertaining to a private figure touches upon a matter of public concern. Phila. Newspapers, Inc. v. Hepps, 475 U.S. 767, 775, 106 S. Ct. 1558, 89 L. Ed. 2d 783 (1986); Dun & Bradstreet, Inc. v. Greenmoss Builders, Inc., 472 U.S. 749, 755-56, 105 S. Ct. 2939, 86 L. Ed. 2d 593 (1985); see also Haueter, 61 Wn. App. at 583. If the plaintiff is a private figure and the defamatory message addresses a matter of purely private concern, the plaintiff need not show actual malice to recover damages. Dun & Bradstreet, 472 U.S. at 763. We have previously reasoned a negligence standard should apply in private figure — private matter defamation cases. Haueter, 61 Wn. App. at 583; see also Dunlap v. Wayne, 105 Wn.2d 529, 534-35, 716 P.2d 842 (1986) (<HOLDING>). On the other hand, if the plaintiff is a
holding that a private figure plaintiff offended by a statement about his private affairs should not be held to convincing clarity standard of proof recognizing private right of action holding that a private right of action exists holding that where statutory remedies exist private employees do not have a private cause of action for violation of state constitutional rights holding that land dedicated for a public street may not be leased to a private entity for private use