In Phillip v. Sterling Home Care, Inc., 103 AD3d 786 (2d Dept. 2013) the Second Department held that "New York does not recognize defamation via compelled self- publication." In that case, the plaintiff was fired from her position as a home health aide on the ground that she had stolen property from the defendants' clients. She argued that in seeking new employment she was forced to disclose that her previous employer accused her of theft. This, she argued, was the basis for her cause of action for defamation by compelled self-publication. The Second Department refused to acknowledge the claim and affirmed the lower court's dismissal of the cause of action finding the cause of action invalid in this State. Id. at 787.