Response or Comment
S. entrusted by the president and general manager of a corporation with the business of obtaining a settlement from plaintiff for a mistakenly supposed shortage in his accounts with the corporation, falsely orally charged him with embezzlement. This charge was made to R., president of another corporation for which the plaintiff was working at the time, and as a step toward getting a settlement by the plaintiff. On the request for a directed verdict, by the defendant, the legal question was presented whether a corporation is liable for slander spoken by the agent of the corporation in the course of his business and in the scope of his authority, and without direction to use, or ratification of the use of, the words spoken, by the directors or chief officers of the corporation. Held: the corporation is so liable. Buckeye Cotton Oil Co. v. Sloan, (1918, U. S. Dist. Ct. Tenn.), 250 Fed. 712. The court says: "We perceive no sound reason why the liability of a corporation for the act of its agent should differ in an action for slander from that in actions for libel, or other torts, and cannot agree with the view expressed in !Southern Ice Co. v. Black, (1916), 136 Tenn. 391, 189 S. W. 861, Ann. Cas. 1917 E. 695.
Wilgus, Horace LaFayette. "Liability of Corporations for Slander." Mich. L. Rev. 17 (1918): 170-2.