Denney v. Northwestern Credit Ass'n

Citations

• 55 Wash. 331
• 104 P. 769
• 1909 Wash. LEXIS 757

Syllabus

<p>Libel and Slander — Libel Per Se — Credit Reports. The report of a mercantile agency is not libelous per se, where it simply gave plaintiff a rating which is stated not to be a credit rating, but that the agency preferred to furnish information upon application at the office; since the words are to be considered in their natural sense, are innocent without the aid of special knowledge, and do not imply malice, or hold the party up to public ridicule or involve moral turpitude.</p> <p>Same — Credit Report to Coerce Payment. It cannot be said, as a matter of law, that such a publication was made to extort money or coerce payment of a debt held by the agency for collection so as to make the same libelous per se, within the rule allowing a recovery in the case of publications showing blackmail on their face.</p> <p>Same — Special Damages — Pleading. In order to render such a publication actionable, the words not being libelous per se, the special damages resulting from loss of credit must be specifically set out, showing the names of parties refusing credit or withdrawing custom, or that it is impossible to do so.</p>