It may be true, in the main, that the life of the law, "has not been logic; it has been experience." Nevertheless, the Courts occasionally develop rules of law with no apparent animation from either. An Ohio decision, Pecyk Adm. v. Semoncheck, furnishes a recent example of one such development and the provocation for yet another examination of the basis for the distinction between written and oral defamation.
Note, A Note on the Distinction between Oral and Written Defamation, 3 Clev.-Marshall L. Rev. 85 (1954)