Hess v. Sparks

It is urged that the opinion handed down in this case wholly ignores the question whether the language spoken by defendant below was a privileged communication, or a qualified privileged communication. It is said that defendant below was one of the board of directors, and one of the largest stockholders of the company, and that the communication was made to the then secretary and treasurer of the company, in relation to an employé of the company.

The answer in this case was a general denial only. No facts in justification, or privilege, or qualified privilege, were alleged as new matter;…