Willfred Coal Co. v. Sapp

It is contended by defendants in error that the declaration fails to allege any special damage resulting in pecuniary loss to plaintiff in error, and that by reason thereof it is fatally defective. The determination of this question depends upon whether the article complained of or any of the statements therein contained are, as applied to the corporation, libelous per se. If the article contains statements which are actionable of themselves when applied to the plaintiff corporation and its credit, trade and business, it was unnecessary to allege special damage, and the demurrer should have…