Calder v. Jones

79 L. Ed. 2d 804 · Supreme Court of the United States · 1984

Facts

Shirley Jones, a California resident, sued Florida-based reporter South and editor Calder for libel in California Superior Court after an article they wrote and edited for the National Enquirer was published nationally, causing her harm in California. Petitioners moved to quash service for lack of personal jurisdiction, arguing their contacts with California were insufficient and that First Amendment concerns should weigh against jurisdiction. The California Court of Appeal reversed the Superior Court's decision to quash, finding jurisdiction proper.

Issue

Can a state court assert personal jurisdiction over out-of-state defendants (a reporter and an editor) whose intentional, allegedly tortious conduct (libel) occurred outside the forum state but was expressly aimed at a resident within the forum state, causing injury there, consistent with the Due Process Clause, and do First Amendment concerns affect this jurisdictional analysis?

Holding

Yes, California courts can assert personal jurisdiction over the Florida-based reporter and editor. The Supreme Court affirmed the California Court of Appeal, holding that jurisdiction was proper based on the defendants' intentional conduct aimed at California, and that First Amendment concerns do not enter into the jurisdictional analysis.

Rule

Personal jurisdiction is proper over defendants whose intentional conduct, though occurring out-of-state, is expressly aimed at a resident within the forum state, causing injury there, and they know the brunt of the injury will be felt in that state. First Amendment considerations do not factor into the jurisdictional analysis under the Due Process Clause.

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