Arthur Garfield Hays, Respondent v. American Defense Society, Inc., Appellants

Summary

The New York Court of Appeals reversed the Appellate Division and affirmed the Special Term, holding that the plaintiff's libel complaint failed to state a cause of action because the pamphlet did not specifically charge him. The court affirmed that innuendo cannot transform non‑libelous words into libel and that a libel must refer directly to the plaintiff.