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, where the magazine circulated 10,000-15,000 copies monthly. The lower courts dismissed the suit for lack of personal jurisdiction, citing Keeton's minimal contacts with New Hampshire, the 'single publication rule,' and the state's unusually long statute of limitations.

Issue

Does the Due Process Clause permit a state to assert personal jurisdiction over a nonresident magazine publisher in a libel action when the publisher regularly circulates magazines in the forum state, even if the plaintiff has minimal contacts with that state and the suit seeks nationwide damages under the 'single publication rule'?

Holding

Yes. The Supreme Court reversed, holding that Hustler's continuous and deliberate exploitation of the New Hampshire market by regularly circulating its magazines there was sufficient to establish personal jurisdiction for a libel action, regardless of the plaintiff's contacts or the application of the 'single publication rule' and the forum's statute of limitations.

Rule

Personal jurisdiction over a nonresident defendant is proper under the Due Process Clause when the defendant has 'minimum contacts' with the forum state, such as continuous and deliberate circulation of a publication, and the cause of action arises from those activities. The plaintiff's lack of contacts with the forum, the 'single publication rule,' or choice-of-law concerns like a long statute of limitations do not defeat jurisdiction otherwise established by the defendant's contacts.

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Case brief last reviewed 2026-05-01. Prepared by CaseReader from the published opinion.