NETHERCUTT COLLECTION v. REGALIA
We hold statements by defendants that plaintiff, an automobile museum president, (1) demanded a commission or a finders fee to which he was not entitled, and (2) was fired because other employees would not work for him and would leave if he stayed, should have been presented to the jury as slander per quod rather than as slander per se. Accordingly, we reverse the judgment in favor of plaintiff. Because the jury found that plaintiff did not suffer actual damages, a necessary element of an action for slander per quod, defendants are entitled to judgment without a retrial.
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