New York Court of Appeals
Julius F. Krug, Respondent v. John Pitass, Appellants
February 27, 1900162 N.Y. 154
Summary
The New York Court of Appeals reversed the lower court's judgment and ordered a new trial, holding that the newspaper article was libelous per se, that punitive damages require particular malice that caused the publication, and that the malice of one defendant cannot be imputed to the others without proof.