Woodhouse v. Powles

Citations

• 43 Wash. 617
• 86 P. 1063
• 1906 Wash. LEXIS 757

Syllabus

<p>Libel and Slander — Reports by Credit Association — Lawfulness. An agreement between members of an association of wholesale grocers, to report delinquent retailers, and refuse them credit until their debt to any member of the association is paid, is not unlawful so as to render any false report libelous per se, especially where the retailer is advised in advance of such agreement.</p> <p>Libel — Actual Damages — Evidence — Sufficiency. A retail grocer who was by mistake reported delinquent to an association of wholesale dealers, who thereupon refused him credit, is not entitled to judgment for more than nominal damages for libel, where it appears that the mistake was discovered the next day and his credit restored, and no claim is made that he suffered from injury to feelings or humiliation or injury to credit, and he was unable to give an estimate of the amount of his losses from being unable to fill certain orders on the .day in question.</p> <p>Damages — Punitive Damages. ■ Punitive or exemplary damages are not recoverable in this state.</p> <p>Appeal — Review—Harmless Error — Damages—Nonsuit Where Plaintiff Entitled to Nominal Damages. Where the sole object of the action is the recovery of damages, it is not prejudicial error to grant a nonsuit upon failure to prove substantial damages, although the plaintiff was shown to be entitled to nominal damages.</p>