Keeton v. Hustler Magazine, Inc.

79 L. Ed. 2d 790 · Supreme Court of the United States · 1984

Facts

Kathy Keeton, a New York resident, sued Hustler Magazine, an Ohio corporation, for libel in New Hampshire. Hustler regularly circulated 10,000-15,000 magazines monthly in New Hampshire, but Keeton had minimal contacts there. The lower courts dismissed for lack of personal jurisdiction, citing Keeton's lack of contacts, New Hampshire's long statute of limitations, and the "single publication rule."

Issue

Can a state assert personal jurisdiction over a nonresident magazine publisher in a libel suit when the publisher regularly circulates magazines in the state, but the plaintiff has minimal contacts with the forum and seeks nationwide damages under the "single publication rule" in a state with a long statute of limitations?

Holding

Yes. The Supreme Court reversed the lower courts, holding that New Hampshire could assert personal jurisdiction over Hustler Magazine. The regular circulation of magazines constituted sufficient minimum contacts, and concerns about the plaintiff's contacts or choice-of-law issues did not defeat jurisdiction.

Rule

Personal jurisdiction over a nonresident defendant is proper when the defendant purposefully directs its activities toward the forum state, such as regularly circulating a publication there, and the litigation arises from those activities. The plaintiff's lack of contacts with the forum or choice-of-law considerations do not negate otherwise valid minimum contacts.

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Case brief last reviewed 2026-04-18. Prepared by CaseReader from the published opinion.