How have courts dealt with negligent defamatory graffiti in the past?

3 An example of such a negligent defamation is found in Hellar v. Bianco (1952) 111 Cal.App.2d 424, 244 P.2d 757. There, the plaintiff's name and telephone number appeared on the wall of the restroom in defendant's tavern with the inscription that plaintiff "was an unchaste woman who indulged in illicit amatory ventures." (Id., at p. 425, 244 P.2d 757.) After being informed of this libelous writing, defendant failed to remove it. This court found whether defendant was guilty of a negligent republication of the libel was a question for the jury and reversed a judgment of nonsuit. (Id., at pp. 426-427, 244 P.2d 757.)