Ogden v. Association of the United States Army

HOLTZOFF, District Judge.

The question presented for decision in this ease is whether from the standpoint of the statute of limitations in an action for libel every sale or delivery of a copy of a book, periodical, or newspaper containing an alleged defamatory statement, creates a separate cause of action; or whether only one cause of action arises which accrues at the time of the first publication of one or more copies of the offending material. To formulate this question in another form, should the so-called modern “single publication rule” be the law of the District of Columbia? The…