Brown & Williamson Tobacco Corp. v. Jacobson
United States Court of Appeals for the Seventh Circuit
713 F.2d 262 (7th Cir. 1983)
Relevant factsFree
News anchor Jacobson and CBS-owned WBBM-TV (defendants) aired a story summarizing an FTC report on cigarette advertising, conveying the overall impression that Brown & Williamson (plaintiff) had adopted a marketing strategy (the "Kennan plan") targeting cigarettes at children, even though the company had specifically rejected that plan and told the network's own reporter so before the story aired. The trial court entered judgment for Jacobson and CBS, and Brown & Williamson appealed.
IssueFree
Whether a summary or paraphrase of source material that, taken as a whole, conveys a defamatory overall message may support a claim for libel per se.