The president of C Company dictated a letter addressed to an unincorporated labor union which contained the statement, "I am getting sick of the damn nonsensical business on the part of a bunch of racketeers." In a libel action against the president and C Company by the union, defendants' motion to dismiss was denied. Held, the word "racketeers" is libelous per se; the unincorporated association may sue without proving special damages, for words libelous per se; dictation to a stenographer was publication. Bradley v. Conners, 169 Misc. 442, 7 N. Y. S. (2d) 294 (1938).
Michigan Law Review,
LIBEL AND SLANDER - "RACKETEERS'' AS LIBEL PER SE - NECESSITY FOR PROOF OF SPECIAL DAMAGES BY UNINCORPORATED LABOR UNION - DICTATION AS PUBLICATION,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol37/iss8/29