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Calder v. Jones

Supreme Court of the United States · 1984 · Civil Procedure

personal jurisdictioneffects testintentional tortspurposeful directionminimum contactsspecific jurisdictioneffects testintentional tort

Facts

Shirley Jones, a California resident who lived and worked in California, sued over an allegedly libelous National Enquirer article written by South and edited by Calder in Florida. The Enquirer was a national publication with over 5 million circulation, including about 600,000 copies sold in California, its largest circulation in any state. The story concerned Jones's California activities, drew from California sources, and allegedly injured her professional reputation and caused emotional distress in California. South wrote the draft and Calder edited and approved it and declined to print a retraction; both were Florida residents with limited other relevant California contacts.

Issue

May California exercise personal jurisdiction over Florida-based employees who wrote and edited an allegedly libelous article when their intentional conduct was aimed at a California resident and the brunt of the injury was suffered in California? Do First Amendment concerns alter the ordinary due process analysis for personal jurisdiction in a libel action?

Rule

A state may exercise specific personal jurisdiction consistent with due process when a defendant's intentional and allegedly tortious conduct is expressly aimed at the forum state, the defendant knows the brunt of the injury will be felt there, and the litigation arises from those forum effects. Jurisdiction must be assessed as to each defendant individually, and employee status does not by itself insulate a defendant from jurisdiction. First Amendment concerns do not enter into the jurisdictional analysis.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Miami, reporter Lena Ortiz wrote an online exposé falsely accusing Denver chef Marcus Wynn of stealing charity funds from restaurants in Colorado. She relied on Colorado interviews, focused entirely on Marcus's Denver business, and knew most of his reputation and clientele were in Colorado.

If Marcus sues Lena in Colorado for defamation and intentional infliction of emotional distress, is Colorado's exercise of personal jurisdiction over Lena most likely proper?

Explanation. Specific jurisdiction is proper where the defendant's intentional, allegedly tortious conduct is expressly aimed at the forum and the defendant knows the brunt of the injury will be suffered there. Here, Colorado is the focal point of both the story and the harm: the article concerns a Colorado resident's Colorado activities, uses Colorado sources, and targets his Colorado-centered reputation. Physical presence in the forum is unnecessary, and employee status does not defeat jurisdiction.