Capps v. Watts

Rhodes, Justice:

This appeal involving an action for libel is from an order of the lower court overruling the defendant’s demurrer to the complaint. The defendant contends that his reference to the plaintiff as a “paranoid sonofabitch” does not, on its face, give rise to a cause of action, the words being simply words of abuse and scurrility. He further asserts that, even if these words can be construed as libelous by reason of extrinsic circumstances, they are not actionable without the pleading of special damage and that the plaintiff has failed to plead such special damage as is legally…