With the exception of statements that are true, Massachusetts courts will not grant summary judgment for a libel defendant unless "the publication is not reasonably capable of any defamatory meaning, and cannot reasonably be understood in any defamatory sense."

TCN Channel Nine Pty. Ltd. 153 The question arose in regard to whether it was defamatory to accuse a medical practitioner of conducting lawful abortions. 154 Justice Glass held, first, that the test must be of an understand it to mean, but that commonly the question is one of fact

An interesting example for the application of the sectorial test to a distinct cultural community is Reiman v. Pacific Development Society. 147 A local newspaper in the Finnish language published an article accusing the plaintiff, a member of the Finnish community in Oregon, of trying to disrupt labor organizations to the advantage of capitalists