Cohagan

In this man-bites-dog story, plaintiff newspaper sued an individual for libel and slander. The trial court sustained a demurrer without leave to amend as to the libel cause of action and granted summary judgment as to the slander cause of action. We shall affirm.

Factual and Procedural Background

On May 25, 1988, the Escalón Times, a small-town newspaper, published articles about each candidate for a local election. The article about candidate Victoria Royster was obviously garbled. Gladys Cohagan (Cohagan), a Royster supporter, wrote a letter to the newspaper accusing it of intentionally garbling the article, presumably to influence the outcome of the election. Cohagan included a check to cover the cost of printing her letter as a full-page advertisement. The paper kept her money and printed her letter as an advertisement. Plaintiffs Live Oak Publishing Company, Inc., a California corporation doing business as the Escalón Times, Stanley L. Cook, owner and publisher, Williams P. Camp, general manager, Richard Myers, editor, and Tom Mauldin, managing editor (collectively Live Oak) sued Cohagan for libel. The paper also sued for slander, based on statements Cohagan made…