New York Court of Appeals

Joseph E. Corrigan, Respondent v. the Bobbs-Merrill Company, Appellant, Impleaded With Another

January 27, 1920228 N.Y. 58

Summary

The New York Court of Appeals reversed the lower court’s judgment and ordered a new trial, holding that a publisher can be liable for libel when the publication is "of and concerning" a plaintiff even without actual intent, that punitive damages require proof of actual malice, and that the trial court erred by admitting testimony about an employee’s knowledge that was not attributable to the corporation.