Janklow v. Newsweek, Inc.

How later courts describe this case

• holding that Congress intended the § 7201 offense to be an offense separate from the misdemeanors in the Code, so § 7201 is a separate offense from both § 7203 offenses and § 7205 offenses
• concluding that Minnesota would recognize defamation by implication
• "even an argument by counsel that the plaintiff in a tort suit will receive worker's compensation is so prejudicial as to warrant a new trial"
• “[W]e choose here to adopt the four factors suggested in Judge Starr’s scholarly opinion [in Oilman ], and to expand them, for reasons we will explain, to include elements of the concurrence by Judge Bork.”
• "[W]e choose here to adopt the four factors suggested in Judge Starr's scholarly opinion [in Ollman ], and to expand them, for reasons we will explain, to include elements of the concurrence by Judge Bork."
• reaching this conclusion from examination of legislative history