Ellsworth v. Martindale-Hubbell Law Directory, Inc.

Ellsworth (plaintiff), a longtime highly rated attorney in Martindale-Hubbell's (defendant's) widely circulated legal directory, saw his rating drop first to "fair" and then to entirely blank (suggesting performance too poor to merit any listing), and his income declined substantially afterward; the trial court required him to prove special damages, and he presented accounting records showing a general decline in his business income following the negative ratings.