New York Court of Appeals

Christopher J. O’Connell, Respondent v. the Press Publishing Company, Appellant

March 23, 1915214 N.Y. 352

Summary

The New York Court of Appeals reversed the Appellate Division and dismissed the libel complaint, holding that the plaintiff failed to allege specific pecuniary damage and that the newspaper articles were not libelous per se. The court explained that a publication not defamatory on its face requires proof of actual damages, which must be pleaded with particularity. Consequently, the complaint was insufficient to sustain a cause of action.