What is the effect of false and defamatory accusations against a person who is neither a public official nor a public figure?

We agree. Only rarely will the report of false and defamatory accusations against a person who is neither a public official nor a public figure provide information of value in the resolution of a controversy over a matter of public concern. On the other hand, the report of such accusations can have a [19 Cal.4th 273] devastating effect on the reputation of the accused individual, who has not voluntarily elected to encounter an increased risk of defamation and who may lack sufficient media access to counter the accusations. As this court has remarked, "[a] reasonable degree of protection for a private individual's reputation is essential to our system of ordered liberty." (Brown v. Kelly Broadcasting Co., supra, 48 Cal.3d 711, 743, 257 Cal.Rptr. 708, 771 P.2d 406.) The availability of a defamation action against the source of the falsehood may be an inadequate remedy if the source is insolvent or otherwise unable to respond in damages. Moreover, it is questionable whether money damages are ever a completely adequate compensation for injury to reputation.