The issue involved in the case of Johanna and Florence is the tort of defamation of character.

Defamation is the publishing of a statement that tends to lower a person in the estimation of right-thinking members of society. Defamation may be either a libel, if the statement is published in a permanent form (e.g., in writing), or slander, if spoken.

Johanna called Florence a thief during a hot argument over a domestic matter. These were spoken words, which did not involve a third party. Johanna’s action, therefore, did not amount to libel since it was not written or published in a permanent form. Thus, Florence cannot successfully sue Johanna for libel.