This section contains the nature of the case and procedural background.

Holbrook (D) and two others owned a newspaper which printed a libel. They handled the publishing, commercial, and advertising aspects of the business, and left the news content to an editor. That editor published a libelous story that the owners did not know about. D and the other owners were indicted for criminal libel. Proof was made at trial that showed that a libelous publication had been made in the newspaper, that D and the others owned the paper and that one of the owners was out of town when the libel was published. No proof of negligence was made. D was convicted. D appealed; the use of strict liability was erroneous.

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