Final answer:
Elmer Gertz was ruled to be a private individual in Gertz v. Robert Welch, Inc., where the Supreme Court allowed states to set defamation liability standards for private individuals as long as no liability is imposed without fault.
Step-by-step explanation:
In the case of Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974), the Supreme Court ruled that Elmer Gertz was a private individual. The Court decided that the states could set their own standards of defamation liability for private individuals, as long as there was no liability without fault and only actual damages could be awarded if the state standard was lower than actual malice.
The significance of this ruling is grounded in the distinction between private individuals and public figures in defamation cases. Public figures must prove that the defamatory statements were made with 'reckless disregard' for the truth or with actual malice, according to the earlier case New York Times v. Sullivan. By contrast, private individuals like Gertz are afforded more protection from defamation under state laws, due to their lesser ability to counteract false statements made about them in the public domain.