Defamation is a very difficult, amorphous claim. Most potential defamation claims are not pursued because it can be very difficult to prove damages. A “plaintiff must prove actual damages in all defamation cases.” Nazeri v. Mo. Valley Coll., 860 S.W.2d 303, 313 (Mo. 1993) . Stated differently, “[p]roof of actual reputational harm is an absolute prerequisite in a defamation action.” Kenney v. Wal-Mart Stores, Inc., 100 S.W.3d 809, 817 (Mo. 2003) Indeed, injury to reputation is a prerequisite to emotional damage in defamation actions. Id. at 813. “Harm to reputation or good name is the essence of [defamation], so the plaintiff can have no recovery in [defamation] for emotional distress or economic loss unless her reputation is implicated. Id.
Hosto is an example of actual reputational harm. In that case – relating to defamatory internet postings – there were financial records linking the defamatory statements with a subsequent loss of business. The Fireworks Restoration Co., LLC v. Hosto, 371 S.W.3d 83, 88 (Mo. App. E.D. 2012). Further, witnesses in the same industry as plaintiff testified that the derogatory online reviews were “almost certain” to damage reputation. Id. at 90. “Awards based on a plaintiff’s testimony alone or on inferred damages are unacceptable.” Id. at 89. But because the testimony of third-parties demonstrated actual reputational injury, the Court upheld a jury verdict of $1 in compensatory damages. Id. 90-01.