Epstein v. Gray Television, Inc.

Brief Fact Summary.

Epstein, a Texas resident, sued Gray Television, Inc. in federal district court in Texas under diversity jurisdiction for a report aired in South Carolina and Georgia.

Synopsis of Rule of Law.

A court may exercise specific jurisdiction over a defendant if the claim arises out of the defendant’s contacts with the state.

Facts.

Benn, a reporter for Gray Television, Inc. (Gray) did a story on malpractice lawsuits against Epstein. Epstein lived in Texas and the report was aired in South Carolina and Georgia. Gray was sued in Federal District Court under diversity jurisdiction and Benn filed a motion to dismiss for lack of diversity jurisdiction.

Issue.

Whether a court may exercise specific jurisdiction over a defendant if the claim arises out of the defendant’s contacts with the state?

Held.

Yes. The motion to dismiss is denied because Benn had sufficient contacts to satisfy due process, including: researching Texas law, contacting the Texas Medical Board, and sending the report to Texas authorities. Benn, however, can seek to change the venue.

Discussion.

The Calder Effects Test provides the standard for personal jurisdiction, where jurisdiction remains proper if the defendant aimed the conduct towards the forum state and the state is the focal point of the effects there.