New York Court of Appeals
Anna F. Ostrowe, Respondent v. Richard L. Lee, Appellant
March 24, 1931256 N.Y. 36
Summary
The Court held that the plaintiff's first cause of action, based on a letter dictated to a stenographer and then transcribed and mailed, constitutes publication of libel. The decision rests on the principle that a defamatory writing is published when read by anyone other than the defamed person, including a stenographer who transcribes the dictation.