publication rule in New Jersey

11 New Jersey opinions name it 2 courts 1974–2018 0 in the last five years

The cases below were cited by New Jersey courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

Case	Followed	Cited
Barres v. Holt, Rinehart & Winston, Inc.green njsuperctappdiv · 1974 · cited in 5 New Jersey opinions naming this issue, 1976–2018 2 sentences 2005For example, in Barres, supra, 131 N.J.Super. at 390 , 330 A. 2d 38 , 320 the Law Division Judge noted that an unscrupulous publisher could take advantage of the single publication rule by making a small distribution of the libelous material at a remote place in order to start the limitations period running, and then make a larger distribution at a later date. 2005For example, in Barres, supra, 131 N.J.Super. at 390 , 330 A. 2d 38 , 320 the Law Division Judge noted that an unscrupulous publisher could take advantage of the single publication rule by making a small distribution of the libelous material at a remote place in order to start the limitations period running, and then make a larger distribution at a later date.	1	5
Churchill v. Stategreen njsuperctappdiv · 2005 · cited in 3 New Jersey opinions naming this issue, 2006–2018 2 sentences 2018In Churchill , the Appellate Division applied the single publication rule to online publications. 378 N.J. 2018In applying the single publication rule, the Appellate Division held that no principled reason justified "treating the Internet differently than other forms of mass media." Id. at 483 , 876 A.2d 311 .	1	3
Brockman v. DETROIT DIESEL ALLISON DIV., ETC.green indctapp · 1977 · cited in 1 New Jersey opinions naming this issue, 2006–2006 1 sentence 2006Motors Corp., 174 Ind.App. 240 , 366 N.E. 2d 1201, 1203 (1977).	1	1
Kwass v. Kerseygreen wva · 1954 · cited in 1 New Jersey opinions naming this issue, 1974–1974 2 sentences 1974If, on the other hand, Montana follows what is defined below as the single publication rule, one cause of action arose upon the first publication or printing of the articles, and no other cause of action can arise out of the publication of the articles." [ 512 P. 2d at 703-704 ] [5] An early case establishing this principle is Brandreth v. Lance, 8 Paige (N.Y.) 24 decided in 1839, and cited in Kwass v. Kersey, 139 W. 1974Va. 497 , 81 S.E. 2d 237, 243 , 47 A.L.R. 2d 695, 704 (Sup. Ct. 1954).	1	1
Dodd v. Harper & Bros.green nyappdiv · 1957 · cited in 1 New Jersey opinions naming this issue, 1974–1974 2 sentences 1974See Dodd v. Harper & Brothers, 3 A.D. 2d 548 , 162 N.Y.S. 2d 419 (App. Div. 1957) (distribution of 25,000 copies of magazine article reprint considered separate publication from single publication of magazine, but single publication in itself to which one year period of limitation might apply). 1974See Dodd v. Harper & Brothers, 3 A.D. 2d 548 , 162 N.Y.S. 2d 419 (App. Div. 1957) (distribution of 25,000 copies of magazine article reprint considered separate publication from single publication of magazine, but single publication in itself to which one year period of limitation might apply).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in New Jersey. Read the followed side critically anyway.

Also cited on this issue (17)

Case	Cited	Years
Gregoire v. G. P. Putnam's Sons green ny · 1948 2 sentences 2005Barres, supra, 131 N.J.Super. at 380-381 , 330 A. 2d 38 ( citing Gregoire, supra, 81 N.E. 2d at 46-47 ). 1974Putnam's Sons, 298 N.Y. 119 , 81 N.E. 2d 45 (Ct. App. 1948); convenience to the parties and courts in consolidating into one action all the damage to plaintiff, Wolfson, supra ; Gregoire, supra, and Zuck, supra ; also Ogden v. Ass'n of United States Army, 177 F. Supp. 498 (D.C.D.C. 1959). *380 In Gregoire v. G.P.	2	1974–2005
Murray v. Plainfield Rescue Squad green nj · 2012 2 sentences 2018In deciding that issue, "we apply the same standard governing the trial court-we view the evidence in the light most favorable to the non-moving party." Murray v. Plainfield Rescue Squad , 210 N.J. 581 , 584, 46 A.3d 1262 (2012). 2018In deciding that issue, "we apply the same standard governing the trial court-we view the evidence in the light most favorable to the non-moving party." Murray v. Plainfield Rescue Squad , 210 N.J. 581 , 584, 46 A.3d 1262 (2012).	1	2018–2018
Petro-Lubricant Testing Laboratories, Inc. green njsuperctappdiv · 2016 2 sentences 2018The panel held that under the single publication rule, a new statute of limitations begins to run only "if a modification to an Internet post materially and substantially alters the content and substance of the article." Id. at 400 , 148 A.3d 441 . 2018The panel held that under the single publication rule, a new statute of limitations begins to run only "if a modification to an Internet post materially and substantially alters the content and substance of the article." Id. at 400 , 148 A.3d 441 .	1	2018–2018
Kotlikoff v. the Community News green nj · 1982 2 sentences 2006C The "threshold issue" in any defamation action is "whether the language used is reasonably susceptible of a defamatory meaning." Kotlikoff v. The Cmty. News, 89 N.J. 62, 67 , 444 A. 2d 1086 (1982). 2006C The "threshold issue" in any defamation action is "whether the language used is reasonably susceptible of a defamatory meaning." Kotlikoff v. The Cmty. News, 89 N.J. 62, 67 , 444 A. 2d 1086 (1982).	1	2006–2006
Brockman v. Detroit Diesel Allison Division of General Motors Corp. green indctapp · 1977 1 sentence 2006Motors Corp., 174 Ind.App. 240 , 366 N.E. 2d 1201, 1203 (1977).	1	2006–2006
Barres v. Holt, Rinehart and Winston, Inc. green nj · 1977 2 sentences 2005Barres v. Holt, Rinehart & Winston, Inc., 131 N.J.Super. 371, 374-375, 379, 390 , 330 A. 2d 38 (Law Div.1974), aff'd o.b., 141 N.J.Super. 563 , 359 A. 2d 501 (App.Div.1976), aff'd o.b., 74 N.J. 461 , 378 A. 2d 1148 (1977). 2005Barres v. Holt, Rinehart & Winston, Inc., 131 N.J.Super. 371, 374-375, 379, 390 , 330 A. 2d 38 (Law Div.1974), aff'd o.b., 141 N.J.Super. 563 , 359 A. 2d 501 (App.Div.1976), aff'd o.b., 74 N.J. 461 , 378 A. 2d 1148 (1977).	1	2005–2005
Firth v. State of NY green ny · 2002 2 sentences 2005Firth v. State, 98 N.Y. 2d 365 , 747 N.Y.S. 2d 69 , 775 N.E. 2d 463 (2002), involved similar facts as the case before us and is instructive on this issue. 2005Ibid. *317 The New York Court of Appeals held that the single publication rule applied to Internet publications and the claim was barred by the applicable statute of limitations.	1	2005–2005
Barres v. Holt, Rinehart & Winston, Inc. green njsuperctappdiv · 1976 2 sentences 2005Barres v. Holt, Rinehart & Winston, Inc., 131 N.J.Super. 371, 374-375, 379, 390 , 330 A. 2d 38 (Law Div.1974), aff'd o.b., 141 N.J.Super. 563 , 359 A. 2d 501 (App.Div.1976), aff'd o.b., 74 N.J. 461 , 378 A. 2d 1148 (1977). 2005Barres v. Holt, Rinehart & Winston, Inc., 131 N.J.Super. 371, 374-375, 379, 390 , 330 A. 2d 38 (Law Div.1974), aff'd o.b., 141 N.J.Super. 563 , 359 A. 2d 501 (App.Div.1976), aff'd o.b., 74 N.J. 461 , 378 A. 2d 1148 (1977).	1	2005–2005
Cimiluca v. Cimiluca green njsuperctappdiv · 1990 2 sentences 1998Id. at 152 , 584 A. 2d 823 . 1998Id. at 152 , 584 A. 2d 823 .	1	1998–1998
Katz v. United States green scotus · 1967 1 sentence 1990Nor do we believe that that presentation by the telephone company of the toll billing records to the county treasurer for payment results in any more of a publication or waiver of privacy than inheres in the fact that the telephone company "in the course of its operations is privy to any information." Id. 91 N.J. at 346 , 450 A. 2d 952 .	1	1990–1990
State v. Hunt green nj · 1982 2 sentences 1990Nor do we believe that that presentation by the telephone company of the toll billing records to the county treasurer for payment results in any more of a publication or waiver of privacy than inheres in the fact that the telephone company "in the course of its operations is privy to any information." Id. 91 N.J. at 346 , 450 A. 2d 952 . 1990Nor do we believe that that presentation by the telephone company of the toll billing records to the county treasurer for payment results in any more of a publication or waiver of privacy than inheres in the fact that the telephone company "in the course of its operations is privy to any information." Id. 91 N.J. at 346 , 450 A. 2d 952 .	1	1990–1990
Lewis v. Reader's Digest Ass'n green mont · 1973 2 sentences 1974In Lewis v. Reader's Digest Ass'n, Inc., Mont., 512 P.2d 702 (1973), pursuant to procedure provided in the rules of the Supreme Court of Montana, that court, in answering a question certified by the United States District Court for Montana hearing a diversity case, [4] adopted the multiple publication rule. 1974If, on the other hand, Montana follows what is defined below as the single publication rule, one cause of action arose upon the first publication or printing of the articles, and no other cause of action can arise out of the publication of the articles." [ 512 P. 2d at 703-704 ] [5] An early case establishing this principle is Brandreth v. Lance, 8 Paige (N.Y.) 24 decided in 1839, and cited in Kwass v. Kersey, 139 W.	1	1974–1974
Wolfson v. Syracuse Newspapers, Inc. green ny · 1939 2 sentences 1974Under this rule the publication has been treated as complete when "the finished product was released by the publisher for sale in accord with trade practice." * * * [ Prosser, op. cit. at 769] The decisions developing the single publication rule suggest the following reasons for its development: To prevent the constant tolling of the statute of limitations and thereby support the legislative determination for a short period of limitation of libel, Wolfson v. Syracuse Newspapers, Inc., 254 App. Div. 211 , 4 N.Y.S. 2d 640 (App. Div. 1938), aff'd per curiam with a strong dissent, 279 N.Y. 716 , 1 1974Under this rule the publication has been treated as complete when "the finished product was released by the publisher for sale in accord with trade practice." * * * [ Prosser, op. cit. at 769] The decisions developing the single publication rule suggest the following reasons for its development: To prevent the constant tolling of the statute of limitations and thereby support the legislative determination for a short period of limitation of libel, Wolfson v. Syracuse Newspapers, Inc., 254 App. Div. 211 , 4 N.Y.S. 2d 640 (App. Div. 1938), aff'd per curiam with a strong dissent, 279 N.Y. 716 , 1	1	1974–1974
Ogden v. Association of the United States Army green dcd · 1959 1 sentence 1974Putnam's Sons, 298 N.Y. 119 , 81 N.E. 2d 45 (Ct. App. 1948); convenience to the parties and courts in consolidating into one action all the damage to plaintiff, Wolfson, supra ; Gregoire, supra, and Zuck, supra ; also Ogden v. Ass'n of United States Army, 177 F. Supp. 498 (D.C.D.C. 1959). *380 In Gregoire v. G.P.	1	1974–1974
Hazel A. Wheeler and Terry Ann Chenoweth, a Minor, by Richard M. Hughey, Her Guardian v. Dell Publishing Co., and Columbia Pictures Corporation green ca7 · 1962 1 sentence 1974In Wheeler v. Dell Publishing Co., 300 F. 2d 372 (7 Cir.1962), the widow and minor daughter of man shot by police officer appealed from a judgment of dismissal of a libel complaint in favor of the author and publisher of Anatomy of a Murder, entered on grounds that the action was barred by one-year statute of limitation of Illinois under the single publication rule.	1	1974–1974
John Zuck v. Interstate Publishing Corp., John Zuck v. Marjorie Bair, Edward Purcell, Martin Goodman and Jean Goodman green ca2 · 1963 1 sentence 1974Putnam's Sons, 298 N.Y. 119 , 81 N.E. 2d 45 (Ct. App. 1948); convenience to the parties and courts in consolidating into one action all the damage to plaintiff, Wolfson, supra ; Gregoire, supra, and Zuck, supra ; also Ogden v. Ass'n of United States Army, 177 F. Supp. 498 (D.C.D.C. 1959). *380 In Gregoire v. G.P.	1	1974–1974
Wolfson v. Syracuse Newspapers, Inc. green nyappdiv · 1938 2 sentences 1974Under this rule the publication has been treated as complete when "the finished product was released by the publisher for sale in accord with trade practice." * * * [ Prosser, op. cit. at 769] The decisions developing the single publication rule suggest the following reasons for its development: To prevent the constant tolling of the statute of limitations and thereby support the legislative determination for a short period of limitation of libel, Wolfson v. Syracuse Newspapers, Inc., 254 App. Div. 211 , 4 N.Y.S. 2d 640 (App. Div. 1938), aff'd per curiam with a strong dissent, 279 N.Y. 716 , 1 1974Under this rule the publication has been treated as complete when "the finished product was released by the publisher for sale in accord with trade practice." * * * [ Prosser, op. cit. at 769] The decisions developing the single publication rule suggest the following reasons for its development: To prevent the constant tolling of the statute of limitations and thereby support the legislative determination for a short period of limitation of libel, Wolfson v. Syracuse Newspapers, Inc., 254 App. Div. 211 , 4 N.Y.S. 2d 640 (App. Div. 1938), aff'd per curiam with a strong dissent, 279 N.Y. 716 , 1	1	1974–1974

Where else courts name it

NY 44 (1912–2025) CA 24 (1943–2026) TX 18 (1937–2024) IL 14 (1978–2025) AR 12 (1903–2016) NJ 11 (1974–2018) IN 11 (1977–2013) PA 11 (1970–2023) CT 10 (1996–2024) FL 9 (1993–2025) GA 8 (1978–2022) MI 7 (1977–2018) LA 6 (1957–2026) OH 5 (2003–2024) CO 5 (1901–2021) ID 5 (2007–2019) MA 5 (2003–2024) KY 5 (1918–2013) VA 5 (1996–2003) MS 5 (1965–2008) AL 4 (1986–2025) DE 4 (2000–2020) TN 4 (1997–1999) WI 4 (1940–2019) WA 4 (2008–2018) HI 4 (1931–2004) MO 4 (1899–2000) IA 3 (1953–2020) NM 3 (2003–2019) MD 3 (1972–2020) NE 3 (2004–2024) OK 2 (2011–2014) MT 2 (1973–2025) MN 2 (1986–1994) OR 2 (1996–2003) AZ 2 (2001–2014) RI 2 (1973–1997)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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