In Van Horne v. Muller, 185 Ill. 2d 299, 313, 705 N.E.2d 898, 235 Ill. Dec. 715 (1998), the plaintiff alleged that a radio deejay defamed him and that the radio station that employed the deejay should have known that he would make false, defamatory statements on the air. The court concluded that the mere fact that the deejay previously engaged in "offensive or outrageous conduct during his radio programs does not establish that he had a propensity to make false, defamatory statements." Van Horne, 185 Ill. 2d at 314. Such "outrageous and offensive conduct" was not sufficient to put the radio station on notice that the deejay would make false, defamatory statements on the air if it hired him. Van Horne, 185 Ill. 2d at 314.