Mr. Chow of New York v. Ste. Jour Azur S.A.

A restaurant guide published by Ste. Jour Azur and its co-authors (defendants) printed a review of Mr. Chow's restaurant criticizing the condiments, the sweet-and-sour pork, the green peppers, the rice, and the number of dishes used to serve Peking Duck. Mr. Chow of New York (plaintiff), the restaurant's owner, sued for libel, and the jury, instructed that liability would follow if any of six specific statements were false, defamatory, and made with malice, awarded $20,000 in damages. The defendants' motion for judgment notwithstanding the verdict was denied, and they appealed, arguing the review was protected opinion and that there was insufficient evidence of malice.