How does the single publication rule apply in defamation cases?

California, United States of America


The following excerpt is from Bryan v. News Corp., B275567 (Cal. App. 2018):

(Shively v. Bozanich, supra, 31 Cal.4th at p. 1245, fn. omitted.)9 "Under the single-publication rule, with respect to the statute of limitations, publication generally is said to occur on the 'first general distribution of the publication to the public.' [Citations.] Accrual at that point is believed to provide adequate protection to potential plaintiffs, especially in view of the qualification that repetition of the defamatory statement in a new edition of a book or newspaper constitutes a new publication of the defamation that may give rise to a new cause of action, with a new accrual date. [Citation.] Under this rule, the cause of action accrues and the period of limitations commences, regardless of when the plaintiff secured a copy or became aware of the publication. [Citations.]" (Id. at pp. 1245-1246, fn. omitted.)

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