The general rule states any repetition of libel or slander is a separate defamatory publication and generates a new cause of action. Several years ago, the California Supreme Court put it this way.
“In general, the repetition by a new party of another person’s earlier defamatory remark also gives rise to a separate cause of action for defamation against the original defamer, when the repetition was reasonably foreseeable. It is the foreseeable subsequent repetition of the remark that constitutes publication and an actionable wrong […], even though it is the original author of the remark who is being held accountable.” [Citations omitted; emphasis added]
Accordingly, assume a plaintiff is aware of the facts giving rise to the cause of action, which accrued before the cause of action on which he is suing. If his or her new claim founds on the same defamatory matter as his or her prior claim, but emerges in a separate publication, the statute of limitations on the later cause of action does not run from the time of accrual of the first. Instead, a new statutory period begins. Defendants and counsel beware.