Dun and Bradstreet, Inc., Petitioner v. Truman O’neil, Respondent

Summary

The Texas Supreme Court affirmed the trial court's instructed verdict, holding that Dun & Bradstreet's "Special Notice" was conditionally privileged because it was sent only to subscribers who had requested credit information within the prior twelve months, and that the plaintiff failed to show actual malice. Justice Reavley dissented, arguing that no privilege exists for publishing false reports without a source.