Section 5.7 Intracorporate Publication

• Library: Tort Law 2016

3. (§5.7) Intracorporate Publication

Missouri law holds that "communications between officers of the same corporation in the due and regular course of the corporate business, or between different offices of the same corporation, are not publications to third persons." Hellesen v. Knaus Truck Lines, Inc., 370 S.W.2d 341, 344 (Mo. 1963). In Hellesen, the Court held that a document written and placed in the company files was not "published" although presumably read by secretaries, file clerks, and other corporate personnel. Id.; see also:

· Perez v. Boatmen’s Nat’l Bank of St. Louis, 788 S.W.2d 296, 300 (Mo. App. E.D. 1990) (communications between two employees of different branches of a single national bank were not "published" for defamation purposes)

· Washington v. Thomas, 778 S.W.2d 792, 797 (Mo. App. E.D. 1989) ("It is well settled in

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