LIBEL AND SLANDER - MENTAL SUFFERING ALONE AS SUSTAINING LIBEL ACTION

In a libel action, the plaintiff proved that the defendant had published a news item in its newspaper falsely imputing to the plaintiff, a Puerto Rican student at Louisiana State University, the authorship of an article written in the student paper deploring the pacifistic attitude of the American youth. The lower court dismissed the plaintiff\u27s bill. Held, the publication by the defendant was not a libel actionable without proof of special damages, and that, while mental suffering alone would constitute special damages, the defendant\u27s publication was not the proximate cause of the plaintiff\u27s suffering. Santana v. Item Co., Ltd., 192 La. 819, 189 So. 442 (1939)