Final answer:
The plaintiff in Milkovich v. Lorain Journal was a private citizen. Critical differences in defamation law apply depending on whether the plaintiff is a public figure or a private individual, affecting the burden of proof required in libel cases.
Step-by-step explanation:
The plaintiff in Milkovich v. Lorain Journal was d) a private citizen.
In the realm of defamation law, the standards set by the Supreme Court in New York Times v. Sullivan require that a public figure must demonstrate that a publisher acted with malicious intent or reckless disregard for the truth when negative statements were made about them. In contrast, a private individual such as the plaintiff in Milkovich v. Lorain Journal, must only argue that the author was negligent in ensuring the accuracy of the information published.
This is because public figures are expected to have a greater capacity to counteract false statements due to their access to channels of effective communication and, hence, must meet a higher standard of proof for defamation claims.