Michigan recognizes the wire service defense. See Howe v. Detroit Free Press, Inc., 555 N.W.2d 738 (Mich. App. Ct. 1996). The court in Howe offers a nice definition of the wire service defense in Michigan: "when a local media organization receives a wire service release, it has a duty to read the release to ensure that the face of the story itself does not contain any inconsistencies. The local media organization also has a duty to refrain from publishing the news story if the news organization knows the story is false or if the release itself contains unexplained inconsistencies. The local media organization does not have a duty, however, to independently verify the accuracy of the wire service release." Howe, 555 N.W.2d at 740-41.
Statute of Limitations for Defamation
The statute of limitations for defamation in Michigan is one (1) year. Mich. Comp. Law § 600.5805(7) (1961).
Each publication typically amounts to a separate cause of action in Michigan. See Grist v. Upjohn, 2 Mich. App. 72 (1965); Celley v. Stevens, 2004 WL 134000 (Mich. Ct. App. 2004). Michigan courts have not decided whether the single publication rule applies in Michigan. For a definition of the "single publication rule," see the Statute of Limitations for Defamation page.
Missouri Defamation Law
Note: This page covers information specific to Missouri. For general information concerning defamation, see the Defamation section of this guide.
Elements of Defamation
The elements of defamation in Missouri are:
2. of a defamatory statement
3. that identifies the plaintiff
4. that is false
5. that is published with the requisite degree of fault, and
6. damages the plaintiff's reputation
Overcast v. Billings Mut. Ins. Co., 11 S.W.3d 62, 70 (Mo. 2000) (en banc).