When can a plaintiff bring a nondefamation claim against a defendant for defamation based on defamatory language?

In addition to section 48a, other statutory and common law restrictions on libel and slander actions have been applied to nondefamation claims when such claims were based on defamatory language. In Grimes v. Carter (1966) 241 Cal.App.2d 694, 50 Cal.Rptr. 808, plaintiff brought an action for invasion of privacy and intentional infliction of emotional distress alleging that defendant had stated to a large number of people that she had engaged in sexual intercourse with several men. The trial court dismissed the complaint because of plaintiff's failure to post the bond formerly required in defamation actions.