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California Codes

Cal. Civil Code § 45a (2026)

Personal Rights

✓ current as of May 2026
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A libel which is defamatory of the plaintiff without the necessity of explanatory matter, such as an inducement, innuendo or other extrinsic fact, is said to be a libel on its face. Defamatory language not libelous on its face is not actionable unless the plaintiff alleges and proves that he has suffered special damage as a proximate result thereof. Special damage is defined in Section 48a of this code.

Notes of Decisions
Cited in 74 cases (21 in the last 5 years), 1950–2026 · leading case: ZL Techs., Inc. v. Doe, 220 Cal. Rptr. 3d 569 (Cal. Ct. App. 2017).
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ZL Techs., Inc. v. Doe, 220 Cal. Rptr. 3d 569 (Cal. Ct. App. 2017). · cites it 3× “Relevant Legal Principles Civil Code section 45 defines libel as "a false and unprivileged publication by writing ..., which exposes any person to hatred, contempt, ridicule, or obloquy, .”
Donald Newcombe v. Adolf Coors Co. Foote, Cone & Belding & Time, Inc., 157 F.3d 686 (9th Cir. 1998). · cites it 3× “Under Cal. Civ.Code § 45a, a plaintiff may only prevail on a claim for libel if the publication is libelous on its face or if special damages have been proven.”
Weinberg v. Feisel, 2 Cal. Rptr. 3d 385 (Cal. Ct. App. 2003). · cites it 2× “rcumstances in which they were made—a result that would be inconsistent with the purpose of the anti-SLAPP statute and would unduly undermine the protection accorded by paragraph 1 of Civil Code section 46, which includes as slander any false and unprivileged communication…”
Downing v. Abercrombie & Fitch, 265 F.3d 994 (9th Cir. 2001). · cites it 4× “Specifically, they maintain that inclusion of their names and likenesses in a section depicting naked and scantily *1010 clothed models caused them shame and embarrassment.”
La Liberte v. Reid, 966 F.3d 79 (2d Cir. 2020). “Civ. Code § 45a. Reid’s argument confuses libel per quod, which imposes the special damages requirement, with libel by implication, which can be libel per se nevertheless.”
Selleck v. Globe Int'l, Inc., 166 Cal. App. 3d 1123 (Cal. Ct. App. 1985). · cites it 3× “Following plaintiff’s failure to *1130 amend within that period, defendant moved for entry of judgment of dismissal.”
Wong v. Jing, 189 Cal. App. 4th 1354 (Cal. Ct. App. 2010). “Civil Code section 45a provides, in relevant part, “A libel which is defamatory of the plaintiff without the necessity of explanatory matter, such as an inducement, innuendo or other *1370 extrinsic fact, is said to be a libel on its face. Defamatory language not libelous on its…”
Song Fi Inc. v. Google, Inc., 108 F. Supp. 3d 876 (N.D. Cal. 2015). · cites it 3× “Despite the shortcomings of this argument, as discussed more fully below, the Court finds that YouTube’s, allegedly libelous statement is not libelous on its face (or “libel per se”).”
Franklin v. Dynamic Details, Inc., 10 Cal. Rptr. 3d 429 (Cal. Ct. App. 2004). “” (Civ. Code, § 45a.) Franklin and FCC contend the three e-mails were actionable as libel and/or trade libel because they contained false statements of fact.”
McGarry v. Univ. of San Diego, 64 Cal. Rptr. 3d 467 (Cal. Ct. App. 2007). “(Civ. Code, § 45a.) A statement can also be libelous per se if it contains a charge by implication from the language employed by the speaker and a listener could understand the defamatory meaning without the necessity of knowing extrinsic explanatory matter.”
Savage v. Pac. Gas & Elec. Co., 21 Cal. App. 4th 434 (Cal. Ct. App. 1993). · cites it 2× “(Civ. Code, §§ 45a and 46; 5 Witkin, Summary of Cal.”
Maidman v. Jewish Publications, Inc., 355 P.2d 265 (Cal. 1960). · cites it 4× “” (Civ. Code, §45a.) "When measured by this test the editorial is unquestionably libelous per se.”
Show all 74 citing cases →
Cal. Civil Code § 45a(d)(1): 1 case
Jordan v. Wonderful Citrus Packing LLC, No. 1:18-cv-00401 (E.D. Cal. Sept. 28, 2020).
Cal. Civil Code § 45a(d)(2): 1 case
Jordan v. Wonderful Citrus Packing LLC, No. 1:18-cv-00401 (E.D. Cal. Sept. 28, 2020).
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