For a statement to be actionable as defamation per quod, it must have resulted in damages to the plaintiff. (See Landmark Communications, Inc. v. Macione, 230 Va. 137 (1985)). In actions for libel and slander in Virginia, a plaintiff must prove the quantum of his damages unless the words at issue are considered defamatory per se. To qualify as defamation per se, the words claimed to be defamatory must fall into one of these four categories:
- Those which impute to a person the commission of some criminal offense involving moral turpitude, for which the party, if the charge is true, may be indicted and punished;
- Those which impute that a person is infected with some contagious disease, where if the charge is true, it would exclude the party from society;
- Those which impute to a person unfitness to perform the duties of an office or employment of profit, or want of integrity in the discharge of the duties of such an office or employment; or
- Those which prejudice such person in his or her profession or trade.