In her petition, the plaintiff alleged that she had been defamed by the defendant and claimed damages therefor. The allegations were that the defendant had executed a letter and false wage assignment and had sent them to the employer of the plaintiff, whereby the plaintiff was embarrassed and humiliated, and held up to ridicule and scorn. The lower court sustained a demurrer to the petition, and an amended petition was stricken from the files and dismissed. Held, a good cause of action had been stated. The court said: "It is not and is not claimed to be a cause of libel per se, but libel per quod. Special damages must be and are alleged." Barteck v. Personal Finance Co. of Toledo, 60 Ohio App. 197, 20 N. E. (2d) 259 (1938).
Michigan Law Review,
LIBEL AND SLANDER - LIBEL PER QUOD - NECESSITY OF SPECIAL DAMAGES,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol38/iss2/20