proposals that were being criticized. No reader could have thought that either the speakers at the meetings or the newspaper articles reporting their words were charging Bres-ler with the commission of a criminal offense. On the contrary, even the most careless reader must have perceived that the word was no more than rhetorical hyperbole, a vigorous epithet used by those who considered Bresler’s negotiating position extremely unreasonable. Indeed, the record is completely devoid of evidence that anyone in the city of Greenbelt or anywhere else thought Bresler had been charged with a crime. Id. at 14-15, 90 S.Ct. 1537 (footnote omitted). ¶ 14 Similarly in the present case, we hold that the use of the term “patronage” cannot imply to the reader that the Rushes were gui 355, 358 (1994) (<HOLDING>). Compare West v. Thomson Newspapers, et al.,
holding that violation of city ordinance does not constitute negligence per se holding that news broadcast which fell within several of the historical categories for per se defamation was not defamatory per se where plaintiffs identity was not shown on its face holding that a newspaper article which suggested that suozzi received political favoritism from his brother the mayor but did not contain a clear assertion that a crime had been committed was not defamatory and could not constitute libel per se holding statements regarding plaintiffs unsatisfactory job performance not defamatory per se holding that statements that plaintiff had had an extramarital affair were defamatory per se