We observe that by reason of Jacron Sales Co. v. Sindorf, 276 Md. 580, 350 A.2d 688 (1976), much of the distinction or difference between libel per se and libel per quod has in fact disappeared. Under Maryland principles of pleading the same rules continue to apply as to the nature of the libel. That is, if the libel is readily apparent as in the situation where one is called a thief, no explanation is necessary, but in the instances which previously would have been a libel per quod, the nature of the libel must be pleaded with the same particularity as formerly. Since nominal or presumed damages no longer exist, in all libel actions Maryland pleading principles require the same type of pleading as to damages as was formerly necessary in libel per quod.
Metromedia, Inc., etc. v. Hillman, et al., 285 Md. 161, 162-3 (1979). As a result,
it is obvious that it is no longer possible in Maryland to recover damages by simply alleging a libel per se.
UPDATE—Hillman was a case certified to the Court of Appeals by the U. S. District Court seeking guidance on how to handle a defamation case under Maryland law.