In accordance with the Ohio Constitution, which provides that a copy of proposed amendments shall be distributed to the electorate together with an argument both for and against the proposed amendments, the governor of the state appointed defendant to prepare arguments against certain proposed amendments to the state constitution. The report contained the statement that plaintiff, sponsor of the proposed amendments, was "a paid lobbyist for the single tax movement." Plaintiff brought suit for libel. Held, that since the defendants were members of the commission appointed by the governor acting in the discharge of their official duty, they were absolutely privileged in making any statement pertinent to the occasion. Bigelow v. Brumley, 138 Ohio 574, 37 N. E. (2d) 584 (1941).
Michigan Law Review,
LIBEL AND SLANDER - EXTENSION OF THE DOCTRINE OF ABSOLUTE PRIVILEGE TO INFERIOR EXECUTIVE AND ADMINISTRATIVE OFFICIALS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol40/iss6/17