Reeves v. Western Co. of N. Am

In Reeves v. Western Co. of N. Am., 867 S.W.2d 385, 395 (Tex. App.-San Antonio 1993), a job applicant sued his potential employer for defamation after he was denied employment for testing positive for alcohol use. In Reeves, there was no evidence that the defamatory statements were published. See id. Instead, the applicant argued that he would be compelled to tell other prospective employers of the defamation. In affirming the trial court's ruling against the applicant, the court of appeals found no evidence of "compelled self-publication," and stated that "Speculation about possible consequences if a prospective employer knew Reeves did not pass the alcohol test will not support this claim." See id.