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033587P.pdf   11/08/2004  Fuqua Homes, Inc.  v.  Raymond Beattie
   U.S. Court of Appeals Case No:  03-3587
   Western District of Missouri   
   Civil Case - libel. District court's grant of judgment as a matter of law 
   in libel action for failure to prove actual damages is affirmed. District 
   court's application of Missouri law was proper because in defamation 
   cases, forum where defamed business has its principal place of business 
   has the most significant relationship. Under Missouri law, actual 
   damages are required. Court's imposition of sanctions against business 
   and counsel is reversed because they were not given fair notice or an 
   opportunity to be heard on the sanctions or the basis upon which 
   sanctions were imposed. Sanctions issue is remanded for further 
   proceedings. [PUBLISHED] [M. Arnold, Author, with Bright and Fagg, 
   Circuit Judges]