Cleveland Leader Printing Co. v. Nethersole

84 Ohio St. (N.S.) 118
CourtOhio Supreme Court
DecidedApril 18, 1911
DocketNo. 11741
StatusPublished

This text of 84 Ohio St. (N.S.) 118 (Cleveland Leader Printing Co. v. Nethersole) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cleveland Leader Printing Co. v. Nethersole, 84 Ohio St. (N.S.) 118 (Ohio 1911).

Opinion

Spear, C. J.

Manifestly the crucial question in the case is whether or not the comment respecting the play called “The Labyrinth,” connected with the statement that Miss Néthersole “had hysterics,” "was libelous per se. One assumption in support of the affirmative of this question is that the article was directed against the plaintiff below,while the contrary claim is that it was directed against the play — the thing itself. Was it directed against the plaintiff? The article is entirely free [128]*128from anything like a libelous attack upon Miss Nethersole. True, she is referred to, and it is stated that she had hysterics. That a woman has fainted, or has had hysterics, is so common an occurrence that a statement to that effect, though untrue, (and the legal effect of the record is that it was in this case untrtie), falls far short of being a libel per se upon such woman, and, leaving that reference to the plaintiff out, the statement is at once but a statement that the play was soundly hissed in London, which was also untrue. As tersely stated by counsel for defendant below; “It” (the article) “has no reference whatever tc Miss Nethersole; it does not say that she is not qualified for her profession; it does not say that Miss Nethersole was received frigidly in Cleveland; it does not say that Miss Nethersole was hissed in London. It says that the play ‘The Labyrinth’ was received frigidly in Cleveland; it says that the play ‘The Labyrinth’ was hissed in London.” Besides, the record, shows that Miss Nethersole was not charged with any lack of character, or of womanliness as a woman; and the court as we understand it found as a' fact, that there was no charge or imputation against her as a woman.

It is, however, claimed that the alleged libel was against her in her profession or business. Here, again, the record contradicts the claim. She was not charged with any lack of ability or character as an actress, nor with any lack of ability or df good judgment as a manager; indeed no’ref-' ererice whatever to her conduct or management in either respect was had, the court having distinctly [129]*129so found and held. The case, therefore, presented a situation where the evidence afforded no ground for an allegation of actual malice, and no ground for a claim that the plaintiff had, by reason of the publication, been subjected to public disgrace, contempt or ridicule, and where the only part of the article which was found to be libelous per se could not be considered as evidence of express malice in respect to criticisms otherwise not unfair or unreasonable. The learned judge held that the balance of the article was not of itself unfair, or unreasonable, and therefore not libelous.

How, then, could the article be treated as a libel upon Miss Nethersole? It is alleged that by reason of this article she has suffered mental distress. Quite likely. But is that a test of whether the article is against her rather than exclusively against the plays? No person, man or woman, can witness sharp criticism of his or her own production, play, book, song or what-not, without more or less mental discomfort, and possibly, in a remote way, some trivial loss. Take a familiar event as an example. Recently there appeared before the American public, on the lecture platform, and in other public places perhaps, a somewhat noted navigator offering - certain proofs of his claim that he had discovered the north pole. Newspapers and scientific journals commented severely upon the proofs, seeking to show that they were bogus. Undoubtedly the navigator felt much distress, and it is quite likely that many people thought less of him because of those attacks, but does that afford any reason for saying that the attack was upon the man ? And though the writer [130]*130of such criticism had, in some non-essential particular, been mistaken as to a fact, would that show, that the attack was on the navigator rather than on the proofs, and give an action as upon a libel per se? It would seem not. And is fair criticism of proofs of an exhibition to be penalized because it may cause some distress or even loss of profits to the exhibitor, especially where the amount of such loss might thereby be saved to the public?

Although the distinction between a libel upon a person and a libel upon that which is the property of a person, is somewhat nice, and although in many cases the distinction is not easy to demonstrate, it often being difficult to apply the settled rules of law to the particular facts of the case, and although the decisions illustrating the subject are not altogether consistent, one with another, yet the rule seems to be well established to the effect that while by the law of libel defamatory language is actionable without special damage when it contains a damaging imputation against one as an individual, or in respect to his office, profession or trade, it is not actionable when it is merely in disparagement of one’s property unless it occasions special damage. Illustrations of the principle are found in text-books and in a number of reported cases, a few only of which will be here cited. In Tobias v. Harland, 4 Wend., 537, being a slander suit for uttering words injurious to a manufactured article, the court held that “where the words are spoken-not of the trader or manufacturer, but of the quality of the article made or dealt in, to [131]*131render them actionable per se, they must import that the plaintiff is guilty of a deceit or malpractice in the making or vending, or of want of skill in the manufacturing of the article,” Marcy, J., stating in the opinion that “no instance can be found, I believe, where an action has been sustained on words for misrepresenting the quality of any single article which a person has for sale, unless special damages are alleged and proved.” The holding in Young v. Macrae, 113 C. L. R., 264, (a libel suit), is to the effect that if a person falsely and maliciously disparages an article which another manufactures or vends, and special damage results, an action will lie although no imputation is cast on the personal or professional character of the manufacturer or vendor, the plain inference being that unless special damage results no- recovery could be had. In Dooling v. Budget Pub’g. Co., 144 Mass., 258, it is held that the publication of an article stating that a dinner furnished by a caterer on a public occasion was “wretched,” and “was served in such a way that even hungry barbarians might justly object,” is not actionable without proof of special damage. In Kennedy v. Press Pub. Co., 41 Hun, 422, it is held that an article severely reflecting on a Coney Island saloon was a libel on the place and not on the proprietor, and, in the absence of any averment of special damage, the facts stated did not constitute a cause of action. Townsend, in his work on slander and libel, sec. 130, observes: “Whether the libel concerns a person or thing, i. e., the affairs of a person, is material in this respect: that language [132]*132when it concerns a person and is discommendatory, is always, in the absence of any evidence to the contrary regarded as uncalled for, as published without any lawful excuse, and is not to be believed and considered as true unless its truth be established, or, as the phrase is, such language is presumed to be malicious and false.

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Cite This Page — Counsel Stack

Bluebook (online)
84 Ohio St. (N.S.) 118, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cleveland-leader-printing-co-v-nethersole-ohio-1911.