Youssoupoff v MGM Pictures (1934)

Law of Torts · Defamation

Facts.

The plaintiff, a Russian princess, complained of a film about Rasputin. The film did not name her, but it portrayed a woman, identifiable by her circumstances as the plaintiff, as having been seduced by Rasputin, a man of vile character.

Issue.

Can a statement be defamatory where the plaintiff is not named, and where the imputation is of something she suffered rather than something she did?

Held.

Yes. It is enough that reasonable people who knew the plaintiff would identify her from the circumstances. And an imputation that causes a person to be shunned or avoided is defamatory even if it imputes misfortune rather than misconduct. Substantial damages were awarded.

Why it matters.

It is the leading case on innuendo and on identification of an unnamed plaintiff, and it is the direct answer to the Russian-princess problem set in 2016 and 2020.

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