Section 5.6 Single Publication Rule

• Library: Tort Law 2016

2. (§5.6) Single Publication Rule

At common law, each publication of a libelous statement gave rise to a separate cause of action. See, e.g., Bigelow v. Sprague, 5 N.E. 144 (Mass. 1886). This rule has almost universally been modified by the "single publication rule." See, e.g., Keeton v. Hustler Magazine, 465 U.S. 770, 777 n.8 (1984). In some states, the single publication rule has been adopted by statute. See, e.g., See, e.g., CAL. CIV. CODE § 3425.3 (Westlaw through 2015 legislation). Missouri, like many other states, has adopted the single publication rule by judicial decision. See Houston v. Pulitzer Pub. Co....