Farrar v. Tribune Publishing Co.

358 P.2d 792, 57 Wash. 2d 549, 1961 Wash. LEXIS 399
CourtWashington Supreme Court
DecidedJanuary 19, 1961
Docket35024
StatusPublished
Cited by12 cases

This text of 358 P.2d 792 (Farrar v. Tribune Publishing Co.) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Farrar v. Tribune Publishing Co., 358 P.2d 792, 57 Wash. 2d 549, 1961 Wash. LEXIS 399 (Wash. 1961).

Opinions

Foster, J.

— The question for decision is whether we should overrule Ott v. Press Pub. Co., 40 Wash. 308, 82 Pac. 403 (1905). It was there held that, in an action for damages on account of a newspaper publication which was libelous per se, the defendant may, under the express provisions of RCW 4.36.130, plead and prove all of the mitigating circumstances, and that the court cannot hold, in the face of this statute, that such pleading should be stricken or the evidence rejected on the theory that only punitive damages can be mitigated. The court adheres to that decision.

Appellant, publisher of the Tacoma News Tribune, appeals from a judgment awarding respondent Farrar $23,000 for written defamation.

During a contest between respondent and George W. Kupka for the state Senate, the Tacoma News Tribune published Kupka’s following paid political advertisement:

“Attention, Voters of the 27th District!
“Farrar Finds ‘Thar’s Gold In Them Thar Bills’
[550]*550“As a member of the legislature, A1 Farrar sponsored Bill No. 21 — ‘More favorable pensions for law enforcement personnel.’
“How did this affect Farrar? We quote from the Tacoma News Tribune, issue of Oct. 2,1956:
“ ‘Under the new computation, A1 Farrar, a former captain of detectives who is now a 35th district legislator, stands to collect $4,100. And his brother, W. E. Farrar, former public safety commissioner and chief of police, will receive $3,047.50.’
“But that isn’t all. Farrar’s bill also increases his pension from $125 per month to approximately $227.50. He did not vote for H. B. 198, however, which would have helped our senior citizens in their declining years!
“If you, the voter and taxpayer, want representation at Olympia
“Vote For Geo. W. Kupka
“For Senator 27th District
“Democrat
“Veteran of World War II
“(Paid Advertisement)”

Farrar sued both Kupka and the newspaper. Eventually Kupka was dropped and, consequently, the judgment is against the newspaper alone for $23,000, from which it appeals.

Three errors are assigned: (1) That the publication was not libelous per se; (2) two assignments which can be considered together, the striking from appellant’s answer the mitigating circumstances, and the exclusion of evidence thereof; and (3) the denial of a new trial because of the claimed excessiveness of the verdict.

The writing as a whole must be considered and the ultimate test is the sense in which it would ordinarily and reasonably be understood by the readers.2 Owens v. Scott Pub. Co., 46 Wn. (2d) 666, 284 P. (2d) 296, certiorari denied 350 U. S. 968, 100 L. Ed. 840, 76 S. Ct. 437; Carey v. Hearst Publications, Inc., 19 Wn. (2d) 655, 143 P. (2d) 857. The writing was actionable without proof of special damage because it imputed misconduct in office, want of official integrity, and want of fidelity to public trust. It tended both [551]*551to deprive respondent of public confidence and to injure him in his profession.

In the complaint, respondent Farrar claimed damage for “humiliation, mental anguish,” and “injury to his feelings.”

The appellant, Tribune Publishing Company, pleaded in its first affirmative defense that the publication complained of was a paid political advertisement, that it had no párt in its preparation, and that it published the same in the genuine and reasonable belief that it was true. All of this was stricken by written order. At the trial, appellant offered evidence in support of its claim of mitigating circumstances but the same ruling was made, and the offered evidence was excluded. Both rulings are assigned as error.

RCW 4.36.130, which was enacted by the first territorial legislature in 1854, provides as follows:

“In an action mentioned in RCW 4.36.120 [libel and slander], the defendant may, in his answer, allege both the truth of the matter charged as defamatory, and any mitigating circumstances to reduce the amount of damages; and whether he proves the justification or not, he may give in evidence the mitigating circumstances.”3

The essence of the respondent’s argument is that mitigating circumstances are material only in a claim for exemplary or punitive damages and that, because such damages have never been allowed in Washington, mitigating circumstances are not material.

But this same argument was rejected in Ott v. Press Pub. Co., supra.

This argument was more plausible in 1905, at the time of the Ott decision, than now because only thirteen years before4 the court first announced that exemplary damages could not be recovered in this state. The additional argument was made in the Ott case that the legislature could not have had in mind actual or compensatory damages, which are not logically susceptible of mitigation, but only exemplary or punitive damages.

[552]*552The verdict in the Ott case was for the defendant newspaper. Upon appeal, the following errors were assigned:

“ . . . in permitting respondent to introduce evidence showing, (1) the directions given by the editor to the reporter who wrote the article; (2) as to conversations between the editor and reporter; (3) as to who accompanied the reporter sent in search of information to which the libel relates; (4) as to how often reports were made to the editor; and (5) as to the motive of respondent in publishing the libel. ...”

The court said:

“Appellants’ theory is that the only damages which could be mitigated would be punitive, their argument being that actual damages, being compensatory only, could not be mitigated, and that evidence of mitigating circumstances should not have been admitted for the purpose of reducing other damages which would be punitive in their character and not recoverable. In answer to this argument it is only necessary to suggest that the doctrine in regard to punitive damages announced in Spokane Truck & Dray Co. v. Hoejer, supra [2 Wash. 45, 25 Pac. 1072 (1891)], did not, when so announced become for the first time a new law of this state, modifying or changing any existing statute. We simply declared and interpreted the law as it already existed prior to the enactment of said § 4939, supra. In the later case of Levy v. Fleischner, 12 Wash. 15, 40 Pac. 384, Dunbar, J., after having distinguished punitive from actual damages, in a further discussion of the different classes of actual damages, said:

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Farrar v. Tribune Publishing Co.
358 P.2d 792 (Washington Supreme Court, 1961)

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Bluebook (online)
358 P.2d 792, 57 Wash. 2d 549, 1961 Wash. LEXIS 399, Counsel Stack Legal Research, https://law.counselstack.com/opinion/farrar-v-tribune-publishing-co-wash-1961.