Ratcliffe v. Evans

After Ratcliffe's (plaintiff) father died, Evans (defendant) published a newspaper article falsely stating that their family business no longer existed; Ratcliffe sued for injurious falsehood, and the trial court ruled in his favor even though he had presented only evidence of a general loss of business rather than any specific, itemized special damages. Evans appealed on the ground that Ratcliffe's failure to plead special damages was fatal to the claim.