Firth v. State of New York
Court of Appeals of New York
775 N.E.2d 463 (N.Y. 2002)
George Firth (plaintiff), a former state employee who handled weapons acquisition, was criticized in a report issued at a press conference by the New York Inspector General; the same day, the State Education Department posted an executive summary linking to the full report on a government website. Firth sued for defamation more than a year later; New York (defendant) moved to dismiss based on the one-year defamation statute of limitations, and the trial court and appellate division agreed, since suit was filed after the limitations period had run from the initial posting.
Whether the single-publication rule applies to defamatory statements made on Internet websites, such that the statute of limitations runs from the initial posting rather than restarting each time the content is accessed.