Final answer:
Elmer Gertz, in Gertz v. Robert Welch Inc., was a private individual. This Supreme Court case allowed states to set their standards for defamation without requiring a private individual to prove actual malice, and only actual damages may be awarded if the state's standard is lower.
Step-by-step explanation:
Elmer Gertz, the plaintiff in Gertz v. Robert Welch Inc., was d) a private individual. The Supreme Court's decision in this case allows states to set their own standards for defamation instead of requiring the plaintiff to prove actual malice when the plaintiff is a private individual, as opposed to a public figure.
The case has had a significant impact on defamation law and the balance between First Amendment rights and the protection of individuals from libelous statements. For private individuals, states cannot impose liability without some level of fault and can award only actual damages if their standards are less demanding than establishing actual malice. The case distinguished between public figures, who must show actual malice to succeed in a defamation lawsuit, and private individuals, who have a lower threshold for proving defamation.