North Dakota has followed that rule. Ellsworth v. Martindale-Hubbell Law Directory, Inc., 66 N.D. 578, 268 N.W. 400, 407 (1936) ("The libel so pleaded is per quod, and as we have held in the original opinion, must be accompanied by allegations of defamatory understanding and special damages in order to present a cause of action."). The requirement of proving special damages in a libel action is a minority rule.
The language of the article must be construed as it would be understood by a reader of ordinary intelligence and perception, and must be stripped of all insinuations, innuendos, colloquium, and explanatory circumstances. It must be considered in its entirety and be defamatory on its face. Gough v. Tribune-Journal Company, 73 Idaho 173, 249 P.2d 192; Corbett v. American Newspapers, 1 Terry 10, 40 Del. 10, 5 A.2d 245; Dilling v. Illinois Publishing Company, 340 Ill.App. 303, 91 N.E.2d 635; Ellsworth v. Martindale-Hubbell Law Directory, 66 N.D. 578, 268 N.W. 400; Snavely v. Booth, 6 W.W.Harr. 378, 36 Del. 378, 176 A. 649. The article published in this case is not libelous per se. Gough v. Tribune-Journal Company, 73 Idaho 173, 249 P.2d 192; Barton v. Rogers, 21 Idaho 609, 123 P. 478, 40 L.R.A., N.S., 681; Jenness v. Co-operative Publishing Co., 36 Idaho 697, 213 P. 351; Sweeney v. Capital News Publishing Co., D.C.Idaho, 37 F. Supp. 355; Wimmer v. Oklahoma Publishing Co., 151 Okl. 123, 1 P.2d 671.