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3.11-2  Libel

Revised to January 1, 2008

Libel is written defamation.  It is the publication of defamatory material by either written or printed words, or by some other form of printed communication that has the same potential harmful characteristics associated with written or printed words.

In this case the plaintiff claims that <insert allegations>.

In order to prove libel, the plaintiff must prove the following

  1. that the defendant published a writing to a third party;

  2. that the writing identified the plaintiff, such that it would be reasonably understood that it was about the plaintiff;

  3. that the writing was defamatory to the plaintiff; and 

  4. that the publication caused harm to the plaintiff.

Only if you find that the plaintiff has proven each of these elements, by a preponderance of the evidence, can you find that the plaintiff has established a case of libel.


Gagnon v. Housatonic Valley Tourism Commission, 92 Conn. App. 835, 847 (2006).


This charge should be preceded by Defamation, Instruction 3.11-1.


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