Section 11 Single Publication Rule

• Library: Damages 2012

Under both English and American common law, each copy of a newspaper edition containing a defamatory statement gave rise to
a separate cause of action. See Bigelow v. Sprague, 5 N.E. 144 (Mass. 1886); Duke of Brunswick v. Harmer, 14 Q.B. 185, 117 Eng. Rep. 75 (1849). Under this “multiple publication rule,” if a newspaper printed 100,000 copies of an edition containing a libelous statement, a plaintiff could bring 100,000 causes of action against the newspaper. Givens v. Quinn, 877 F. Supp. 485, 487–88 (W.D. Mo. 1994); Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 380–81 (N.Y. 1981) (explaining the multiple publication rule and its evolution to the single publication...