Emmens v. Pottle
Dissemination. In Emmens v. Pottle
P alleged that a magazine sold at the defendants’ newsstand in London defamed him. P sued D for libel. Jury brought in a verdict for D after finding they were unaware of the defamatory content. P appealed:
That the defendants were innocent disseminators of a thing which they were not bound to know was likely to contain a libel. That being so, I think the defendants are not liable for the libel.
A newspaper is not like a fire; a man may carry it about without being bound to suppose that it is likely to do an injury