In November, 1941, defendant book publishers commenced distribution of a book containing allegedly libelous statements concerning plaintiff. Thereafter, there were seven additional printings, the last in December, 1943, distribution of which began in March, 1944. Although more than 12,000 copies of the book were sold prior to this reprinting, only 60 copies were sold from stock during the year immediately preceding July 2, I 946, the date plaintiff instituted his action. To determine whether the action was barred by the statute of limitations, the following question was certified to the New York Court of Appeals: "Do sales from stock by a book publisher of copies of a book containing libelous material constitute republications of the libelous matter, so as to give rise to new causes of action . . . where copies sold are from an impression made and released for wholesale distribution more than one year prior to the dates of such sales?" Held, no. Three judges dissented. Plaintiff's action was barred by the statute. Gregoire v. G. P. Putnam's Sons, 298 N.Y. 119, 81 N.E. (2d) 45 (1948).
W. M. Myers,
LIBEL-LIMITATION OF ACTIONS-"SINGLE PUBLICATION RULE" EXTENDED TO INCLUDE BOOKS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol47/iss3/22