Horsley, the owner of a dry cleaning store, lived next door to Eardly, who ran a competing dry cleaning store in the same town. The two quarreled frequently and became enemies. One summer night Eardly composed, printed, and secretly posted around town a flyer accusing Horsley of dealing drugs out of
Horsley's store. The accusation was untrue and defamatory. Several witnesses saw Eardly posting the flyers.
What kind of damages could Horsley collect from Eardly in a lawsuit?