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.
Cal. Civ. Code § 45a
PERSONAL RIGHTS
Applied in 52 court decisions — leading case 52 Cal. 2d 536 - MacLeod v. Tribune Publishing Co. (1959)
Most recently applied in Devin Nunes v. Ryan Lizza (January 2025)
Added by Stats. 1945, Ch. 1489.
How often courts cite this section
Court decisions citing this, by year. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Official source: California Legislative Information. Reproduced from public-domain California statutes; confirm against the official source for the current text. Not legal advice.