Richard M. Patch v. Playboy Enterprises, Inc. And Frank Browning

McMILLIAN, Circuit Judge,

concurring.

I concur with the result reached by the majority and I feel compelled to state separately my reasons for so concurring. I part company with the other members of this panel concerning the use of the Missouri venue cases. While I concede these venue cases are not dispositive, the analogy between Missouri’s venue and borrowing statutes is helpful in determining how Missouri courts would decide where appellant’s cause of action for libel accrued.

Choice of Law — Which Statute of Limitations Governs'!

The district court correctly phrased the second issue presented as “where did Mr. Patch’s libel action against these defendants accrue?” All parties agree that the Missouri state courts have not specifically decided the question where a cause of action for libel accrues for statute of limitations purposes. Under the doctrine of Erie Railroad Co. v. Tompkins, 304 U.S. 64, 58 S.Ct. 817, 82 L.Ed. 1188 (1938), and Guaranty Trust Co. v. York, 326 U.S. 99, 65 S.Ct. 1464, 89 L.Ed. 2079 (1945), in diversity jurisdiction cases the federal courts are required to follow the conflicts of law rules of the highest court of the state in which they sit. Furthermore, decisions made by state courts are controlling as to the meaning and extent of their statutory requirements. Id. at 104, 65 S.Ct. at 1467; Hicklin v. Coney, 290 U.S. 169, 171, 54 S.Ct. 142, 143, 78 L.Ed. 247 (1933). See also Meredith v. Winter Haven, 320 U.S. 228, 234-36, 64 S.Ct. 7, 10, 88 L.Ed. 9 (1943); Challoner v. Day & Zimmermann, Inc., 546 F.2d 26 (5th Cir. 1977) (per curiam); Korzetz v. Amsted Industries, Inc., 472 F.Supp. 136 (E.D.Mich.1979). Thus, a federal court may not ignore the applicable statutory provisions of state law even though the federal court may disagree with the state court’s construction and the state court’s construction is in conflict with decisions of other states having the same statutory provisions. Graham v. White-Phillips Co., 296 U.S. 27, 56 S.Ct. 21, 80 L.Ed. 20 (1935); Stueve v. American Honda Motors Co., 448 F.Supp. 167 (D.Kan.1978).

For reversal appellant argues that the Missouri statute of limitations governs because the situs of the injury was the domicile of appellant, that is, according to appellant, the place where the cause of action accrued or originated. It is appellant’s contention that to hold otherwise would be to deny Missouri citizens the benefits of Missouri laws.

Appellees argue that the choice of law question is governed by whether the Missouri courts would adopt the single publication rule in this context. See Hartmann v. Time, Inc., 166 F.2d 127, 132 (3d Cir. 1947), cert. denied, 334 U.S. 838, 68 S.Ct. 1495, 92 L.Ed. 1763 (1948). According to appellees, if the single publication rule is applicable, then the cause of action necessarily accrued in Illinois, the state of publication.

At this juncture it is necessary to point out that my analysis in this case differs from that suggested by either appellant or appellees. My concurrence examines the operative effect of the Missouri borrowing statute and the construction given to it by Missouri appellate courts in libel actions. I do not apply the approach suggested by the Restatement, although it has been adopted by Missouri in addressing choice of law problems in other contexts. See Restatement (Second) of Conflicts of Laws §§ 142, 143 (1971). As the majority correctly points out, borrowing legislation has been seen as a permissible method legislators may use to instruct the courts in their dealings with limitation problems dealing with conflicts of law. Borrowing statutes, when applicable, largely preempt the court’s examination into alternative conflicts of law theories because the statute requires a mechani*759cal and uniform result intended to diseour-age forum shopping.1

The Missouri borrowing statute provides that “[W]henever a cause of action has been fully barred by the laws of the state, territory, or country in which it was originated, said bar shall be a complete defense to any action thereon, brought in any of the courts of this state.” Mo.Rev.Stat. § 516.190 (1978). The general rule is that, if plaintiff’s action is barred by the statute of the state where the cause of action arose, it is also barred in Missouri. Farthing v. Sams, 296 Mo. 442, 247 S.W. 111 (1922).2 See also Jenkins v. Thompson, 251 S.W.2d 325 (Mo. 1952).

Where the issue has been the construction of its statutory venue provision, Mo.Rev. Stat. § 508.040 (1978),3 the Supreme Court of Missouri has consistently held that “plaintiff’s cause of action accrues at the principal place of publication.”4 Litzinger v. Pulitzer Publishing Co., 356 S.W.2d 81, 84 (Mo.1962), cert. denied, 374 U.S. 831, 83 S.Ct. 1872, 10 L.Ed.2d 1053 (1963); McClung v. Pulitzer Publishing Co., 279 Mo. 370, 214 S.W. 193, 196-99 (1919) (banc); Houston v. Pulitzer Publishing Co., 249 Mo. 332, 155 S.W. 1068, 1070 (1913). See also Jaffe v. Dolan, 264 F.Supp. 845, 848 (E.D.N. Y.1967), citing Buckley v. New York Post Corp., 373 F.2d 175 (2d Cir. 1967); Banks v. King Features Syndicate, 30 F.Supp. 352, 354 (S.D.N.Y.1939); Annot., 20 A.L.R.3d 942 (1968) (for diversity cases regarding venue).

In Litzinger v. Pulitzer Publishing Co., supra, 356 S.W.2d at 84 — 86, the plaintiff initiated a cause of action for libel based upon a newspaper article published in the City of St. Louis. The plaintiff argued that his cause of action accrued in St. Louis County, however, because the editorial in question had attacked plaintiff in his capacity as sheriff in St. Louis County and thus the only harm suffered took place in the county. The Missouri Supreme Court rejected plaintiff’s argument, holding that an action for libel accrues at the place of first publication, not where appellant suffered the most harm as a result of the publication.

By analogy to the venue cases, I believe appellant’s action for libel against Playboy “accrued,” within the meaning and application of the Missouri borrowing statute, in Chicago, Illinois, the magazine’s principal place of publication.

I am fully aware that borrowing statutes and venue statutes have different purposes. Borrowing statutes are primarily designed to prevent a plaintiff from forum shopping to gain more time to initiate his or her cause of action. On the other hand, venue statutes are designed to protect the defendant against the risk that the plaintiff will select an unfair or inconvenient forum for trial.

Were it not for the fact that Missouri courts have never determined where a libel action accrues when a nonresident publisher circulates nationwide allegedly defamatory statements about a Missouri resident, I *760would agree with the majority that the venue cases serve no useful purpose. But because this issue has never been dealt with squarely, I find it more persuasive to rely in part upon a consistent line of Missouri venue cases that have held that “plaintiff’s cause of action accrues at the principal place of publication,” rather than to rely solely upon a bald declaration concerning the anti-forum shopping policy that underlies all borrowing statutes.

. For the most comprehensive discussion of borrowing statutes, see Vernon, Statutes of Limitation in the Conflict of Laws: Borrowing Statutes, 32 Rocky Mtn.L.Rev. 287 (1960); see also R. Leñar, Conflict of Laws § 66 (1959); 3 S. Rabel, the Conflict of Laws: A Comparative Study 475-524 (1950).

. Statute of limitations may be raised as a defense in libel actions by motion to dismiss where the complaint shows on its face that the action has not been instituted within the limitations period and it is apparent that there is no genuine factual controversy surrounding the question of the availability of the defense. Tanner v. Presidents-First Lady Spa, Inc., 345 F.Supp. 950, 954 (E.D.Mo.1972).

. 508.040. Suits against corporations, where commenced. — Suits against corporations shall be commenced either in the county where the cause of action accrued, or in case the corporation defendant is a railroad company owning, controlling or operating a railroad running into or through two or more counties in this state, then in either of such counties, or in any county where such corporations shall have or usually keep an office or agent for the transaction of their usual and customary business.

. For purposes of this case, I need not enter the debate surrounding what events constitute a “publication.” It is sufficient to note that the first printing, the first communication to a third party, and the first sale were made in Chicago.