Note:
Donald R. Joseph, Jr., Absolute Judicial Privilege Extends to Verbatim Publication by West Publishing Company of Allegedly Defamatory Judicial Opinion, 55 TEXAS L. REV. 1103 (1977).
 

Abstract:
In its Federal Supplement, West Publishing Company printed the defamatory comments made by a federal district court judge about the motives of the plaintiff even after a disciplinary board vindicated the plaintiff’s conduct. In Lowenschuss v. West Publishing Co., 542 F.2d 180 (3d Cir. 1976), the court held that the defendant’s verbatim publication of judicial opinions and decisions serves as intrinsic judicial function and is absolutely privileged. Joseph comments that using the first amendment right to freedom of the press would have avoided the problems inherent in bringing a defendant under the legislative, executive, or judicial privileges, while still maintaining the desired protection for verbatim reports of judicial opinions.