It all depends on what the meaning of "struggling" is...

Phil Spector has been found guilty of 2nd-degree murder of Lana Clarkson, who is described by the NY Times as a "struggling actress."

She was 40 at the time of her death, and the highlights of her career, according to the Times, were that she "starred in a 1985 cult hit, Barbarian Queen, and had a bit part in Fast Times at Ridgemont High in 1982."

THAT'S struggling? A starring role in a little-known movie a quarter of a century ago?

Wow, what's the definition of a former actress?