The wife of a candidate for a state assembly seat was not a limited public figure merely by being married to a candidate for public office.  Here, the only evidence of the wife’s involvement in her husband’s campaign was were marching with her husband, carrying a campaign sign, during the Vietnamese-American community’s annual Lunar New Year parade.  That minimal involvement in the campaign did not make her a limited purpose public figure.  She had not voluntarily thrust herself into the public light or acquired substantial media access.  Since the wife was not a public figure, she did not have to prove actual malice to succeed on her defamation claim.