Ogden v. Association of the United States Army
United States District Court for the District of Columbia
177 F.Supp. 498 (D.D.C. 1959)
Relevant factsFree
The plaintiff published a book containing allegedly defamatory content about the defendant in November 1955, but the defendant did not sue until June 1959, well beyond the District of Columbia's one-year libel limitations period; the plaintiff moved for summary judgment based on the statute of limitations.
IssueFree
Whether each individual sale or delivery of an additional copy of a previously published book constitutes a new publication giving rise to a fresh cause of action for libel, restarting the limitations period.