recognizing the last class and holding that “such words are actionable per se if written, though not if spoken orally”
How later courts described this case
- recognizing the last class and holding that “such words are actionable per se if written, though not if spoken orally”
- limiting absolute privilege to legislative proceedings, "judicial proceedings in official courts of justice," official acts of state or federal executive offices and acts done in the exercise of military or naval authority
- finding Ohio's legislative immunity limited to instances where a defamatory publication is ”pertinen[t] to the occasion of the privilege”
- finding no cause of action for conspiracy to commit defamation where no underlying cause of action for defamation exists
Written by the judges who cited it.
The opinion
Williams, J.,
concurs in paragraphs 2, 3 and 4 of the syllabus and is of the opinion that the judgment of the Court of Appeals should be reversed and tha,t of the Court of Common Pleas affirmed.