by Michael Fox
Almost every employment defamation case features an element of grapevine knowledge, that is never attributable to any source. Although it seems obvious that such unattributed statements are not a sufficient foundation for a defamation claim, because it shows up in so many cases, it is always nice to have a case which has that explicit holding. Trostle v. Combs (Tx. Ct. App. - Austin 4/3/03) does so. It also threw out a more specific allegation for lack of evidence based on personal knowledge.