Court of Appeals for the D.C. Circuit January 30, 1996, 94-7137 (Robert C. McFarlane v. Esquire Magazine)

STEPHEN F. WILLIAMS, Circuit Judge:

In the late ’80s and early ’90s articles appeared in the American press asserting an “October Surprise” — a scheme by members of the 1980 Reagan-Bush campaign team to thwart President Carter’s efforts to negotiate

*1299

the release of Iran’s American hostages by inducing the Iranians to delay their agreement.