Charles C. Ward and Mary B. Ward, Plaintiffs-Respondents v. Johanan Zelikovsky, Defendant-Appellant

Summary

The Supreme Court of New Jersey reversed the Appellate Division and remanded for dismissal, holding that the defendant's statements calling the plaintiffs a "bitch" and alleging they "hate Jews" are non‑actionable name‑calling, not slander per se, and that the plaintiffs failed to prove the special damages required for any slander recovery. The Court emphasized the need for verifiable factual content and special damages, and noted that expanding slander per se categories to include bigotry is improper. Justice Stein concurred in the judgment but disagreed with the majority’s conclusion that the plaintiffs’ claims fail to state a cause of action.