The elements of a cause of action for defamation are (a) a false statement that tends to expose a person to public contempt, hatred, ridicule, aversion, or disgrace, (b) published without privilege or authorization to a third party, (c) amounting to fault as judged by, at a minimum, a negligence standard, and (d) either causing special harm or constituting defamation per se. Where the plaintiff is a public figure, the plaintiff is required to prove, by clear and convincing evidence, that the defamatory statements were published with actual malice. In an action for libel or slander, the particular words complained of shall be set forth in the complaint, pursuant to CPLR 3016[a], and the complaint must aallege the time, place, and manner of the false statement and specify to whom it was made.
Worob v. Campbell, NY Slip Op 00813 (2d Dep't February 11, 2026)
