Agriss v. Roadway Express, Inc.

Agriss (plaintiff), a truck driver and union shop steward, sued his employer Roadway (defendant) after it issued him a false written warning accusing him of opening company mail — an accusation that spread through the company and damaged his reputation for honesty among coworkers and union officials for nearly a year. The trial court held the accusation wasn't defamatory "on its face," so Agriss needed to plead extrinsic facts and prove special (economic) damages; because he hadn't done so, the court dismissed his complaint.

Whether a plaintiff seeking to recover for libel under Pennsylvania law must prove special damages.