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 over an article published in the National Enquirer. Petitioners, who wrote and edited the article in Florida, moved to quash service for lack of personal jurisdiction, arguing their limited contacts with California and First Amendment concerns. The California Court of Appeal reversed the Superior Court's decision to quash, finding jurisdiction proper.
Issue
Can a California court exercise personal jurisdiction over out-of-state newspaper reporter and editor for an allegedly libelous article published nationally but causing harm in California, and do First Amendment concerns weigh against such an assertion of jurisdiction?
Holding
Yes, California courts can assert personal jurisdiction over the reporter and editor. The Court affirmed the California Court of Appeal, holding that First Amendment concerns do not enter into the jurisdictional analysis.
Rule
Personal jurisdiction is proper over a defendant whose intentional conduct, expressly aimed at the forum state, causes injury there, and the defendant knows the brunt of that injury will be felt in the forum state. First Amendment considerations are already incorporated into substantive libel law and do not provide additional protection at the jurisdictional stage.
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