Weaver v. Beneficial Finance Co.

98 S.E.2d 687, 199 Va. 196, 1957 Va. LEXIS 179
CourtSupreme Court of Virginia
DecidedJune 14, 1957
DocketRecord 4677
StatusPublished
Cited by37 cases

This text of 98 S.E.2d 687 (Weaver v. Beneficial Finance Co.) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Weaver v. Beneficial Finance Co., 98 S.E.2d 687, 199 Va. 196, 1957 Va. LEXIS 179 (Va. 1957).

Opinions

Snead, J.,

delivered the opinion of the court.

Wesley James Weaver, appellant, instituted action on June 8, 1956 against Beneficial Finance Co., Incorporated and R. S. Costigan, appellees, for compensatory and punitive damages in the sum of $50,000 “due to the republication on or about March 21, 1956,” of a certain false, insulting and libelous letter written by appellees to appellant’s employer on February 23, 1955.

Appellees filed a special plea in bar in which they averred that the action was barred by the statute of limitations. Appellant moved to dismiss the plea. The trial court overruled the motion to dismiss, sustained the special plea in bar and dismissed the motion for judgment with prejudice, to which action of the court appellant excepted. We granted plaintiff a writ of error.

No evidence was heard and the case is before us, as it was before the trial court, upon the motion for judgment and the special plea in bar. It is conceded by the parties that the one year statute of limitations applies (§ 8-24, Code 1950), and the sole question presented is whether or not the cause of action arose within one year from the date of institution of this action.

Appellant alleged in his motion for judgment that as additional security he gratuitously endorsed a note drawn by William E. Webster and Mary T. Webster, his wife, secured by a deed of trust on certain personal property for a loan of $300 advanced by the appellees to the Websters; that on January 29, 1955 appellees, through their agent, informed appellant that the Websters had defaulted in the monthly payments due on their note and called upon appellant to pay the balance due of $95, at which time appellant paid $5.20 and agreed to pay the then balance on or about June 15, 1955 which was satisfactory with appellees; that on February 23, 1955 appellees unlawfully and with malice wrote an insulting and libelous letter to Industrial Relations Officer, Naval Air Station, Norfolk, Virginia, appellant’s employer, with intent to force payment which was not [198]*198due; that the libelous letter in question was republished on or about March 21, 1956 before a promotion board convened to consider appellant’s record, at which time the contents of the letter were first made known to appellant; that the letter suggested that appellant was and is dishonest, insolvent and one to whom credit should not be extended; that it attacked his reputation for integrity; that appellees knew the libelous letter would be a permanent part of his record and would be republished in the future; that the republication of the letter was the natural and probable consequence of the appellees’ act, and that the letter written and signed by appellee Costigan, manager of appellee Beneficial Finance Co., Incorporated, who was acting in the ordinary course of his employment, was authorized and ratified by appellee Beneficial.

The alleged libelous letter which was incorporated in the motion for judgment, is dated February 23, 1955, and reads as follows:

“On September 23, 1953, Mr. Weaver, who gave his employment as above secured a loan of $300.00. This money was lent on a fifteen months contract with payments of $24.29 per month. At no time has Mr. Weaver honored his contract promptly and now his account is four months past due. He refuses to answer any correspondence and personal calls have no effect.
“We realize that Government agencies can take no cognizance of a debt complaint against an employee beyond acknowledging receipt of the communication and that there is no legal jurisdiction over Federal pay excepting those matters relating to Government claims. However, it is understood that the Department of the Navy expects all Naval personnel to discharge acknowledged and just obligations and desires to cooperate with persons and firms when difficulty in obtaining settlements is encountered.
“Instigation of the removal of Mr. Weaver from his employment is not the intent of this company. However, we feel that if someone in a supervisory position will explain his liabilities and the possible effects of same upon himself, he will then be induced to bring his account to date and pay promptly thereafter.
“Any consideration given us in regard to this matter will be greatly appreciated.”

Appellant’s cause of action is grounded upon the republication of the letter, on March 21, 1956. He contends that appellees are liable since the republication was the natural and probable consequence of their act or that they actually or presumptively authorized [199]*199or directed its republication and that the statute of limitations did not begin to run until March 21, 1956, the date of such republication. On the other hand, appellees maintain that the cause of action against them arose on February 23, 1955, the date the letter was written or published, and not on March 21, 1956, the date it was republished by a third party.

It is well settled that the author or originator of a defamation is liable for a republication or repetition thereof by third persons, provided it is the natural and probable consequence of his act, or he has presumptively or actually authorized or directed its republication. This is based upon the principle that such republication constitutes a new cause of action against the original author. However, the original author is not responsible if the republication or repetition is not the natural and probable consequence of his act, but is the independent and unauthorized act of a third party.

In 53 C. J. S., Libel and Slander, § 85, p. 137, it is stated:

“The author of the defamation is liable for any secondary publication which is the natural consequence of his act; and this rule applies both to libel and to slander. On the other hand, the originator of a defamation is not libel for any repetition or republication thereof, or any additional circulation given to it which is not the natural consequence of his act, but results from the independent and unauthorized act of another, that is, where defamatory matter is republished by a person other than the original author, the author is not liable therefor unless the republication is the natural and probable consequence of his own act, or unless he has actually or presumptively authorized or ordered its repetition. Thus, the publisher of a newspaper or magazine has been held not responsible for the acts of third persons who, after the original publication, sell copies of the newspaper or magazine to others.”

Newell, Slander and Libel (4th Ed.) § 303, p. 339, defines the author’s liability for repetition by third persons as follows: [200]*200of his act, and it may be that the repetition of a slander or libel may be the natural consequence of the original publication, in which case the author of the original defamatory matter would be liable. And where the words declared on are slanderous per se their repetition by others is the natural and probable result of the original slander.”

[199]*199“Under the weight of authority the author of a libel or slander is not liable for its voluntary and unjustifiable repetition, without his authority or request, by others over whom he has no control, either as on a direct cause of action or by way of aggravation of damages, and such repetition cannot be considered in law a necessary, natural and probable consequence of the original slander or libel. But the rule has one important qualification.

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Bluebook (online)
98 S.E.2d 687, 199 Va. 196, 1957 Va. LEXIS 179, Counsel Stack Legal Research, https://law.counselstack.com/opinion/weaver-v-beneficial-finance-co-va-1957.