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FELLOWS v. NATIONAL ENQUIRER, INC.

Docket No. L.A. 32082.

42 Cal.3d 234 (1986)

721 P.2d 97

228 Cal. Rptr. 215

ARTHUR FELLOWS, Plaintiff and Appellant, v. NATIONAL ENQUIRER, INC., Defendant and Respondent.

Supreme Court of California.

July 31, 1986.

Attorney(s) appearing for the Case

COUNSEL

Marvin Gross, James M. Simon and Grayson & Gross for Plaintiff and Appellant.

John G. Kester, Richard S. Hoffman, Williams & Connolly, Richard H. Borow, Jon W. Davidson and Irell & Manella for Defendant and Respondent.

OPINION

BROUSSARD, J.

Under Civil Code section 45a, language that is defamatory only by reference to extrinsic facts is not actionable unless the plaintiff can prove special damages.1 Special damages are defined in Civil Code section 48a as damages to property, business or occupation.2 In this case we must decide whether the special...

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