Reroy B. Crane, Respondent v. James Gordon Bennett, Appellant

Summary

The New York Court of Appeals affirmed the Appellate Division's judgment, holding that a newspaper proprietor who delegates full management to a general manager is liable for punitive damages for libel published by his employees, and that proof of falsity of a libelous statement is sufficient evidence of malice to permit a jury to award punitive damages. The court also clarified that the trial court's jury instruction on this issue was proper.