In McKinney v. County of Santa Clara (1980) 110 Cal.App.3d 787, a former deputy sheriff brought a defamation action against his former employer. The defamatory statements were made in reviewing his job performance and formed the basis for his dismissal. Plaintiff conceded he made the republications, but claimed they were not voluntary but required as a practical matter as part of applying for a new job. (Id. at pp. 792-793.) The trial court dismissed the action because plaintiff himself had republished the defamatory statements. (Id. at p. 798.) The appellate court reversed, finding a triable issue of fact on the issue of publication. (McKinney v. County of Santa Clara, supra, 110 Cal.App.3d 787, 798.) The court adopted a theory of compelled republication that applied in two contexts. First, where the originator had reason to believe a letter sent to the defamed containing libel will fall into the hands of a third party before the defamed reads it. (Id. at p. 796.) The second context "is where the originator of the defamatory statement has reason to believe the person defamed will be under a strong compulsion to disclose the contents of the defamatory statement to a third person after he has read it or been informed of its contents." (Ibid.) "The rationale for making the originator of a defamatory statement liable for its foreseeable republication is the strong causal link between the actions of the originator and the damage caused by the republication. This causal link is no less strong where the foreseeable republication is made by the person defamed operating under a strong compulsion to republish the defamatory statement and the circumstances which create the strong compulsion are known to the originator of the defamatory statement at the time he communicates it to the person defamed." (Id. at pp. 797-798.) The rule of McKinney "has been limited to a narrow class of cases, usually where a plaintiff is compelled to republish the statements in aid of disproving them." (Live Oak Publishing Co. v. Cohagan (1991) 234 Cal.App.3d 1277, 1285.)