Calder v. Jones

Brief Fact Summary.

Respondent sued Petitioners for libel in California state court. Petitioners objected to the California state court’s jurisdiction.

Facts.

Respondent, an actress, brought a libel action against Petitioners, an editor and a reporter, in California state court. Petitioners, who were both Florida residents, objected to California jurisdiction. The reporter traveled to California frequently on business. He claimed no visits were made for the story about Respondent (although the trial court found he made one such visit), and that his research for the story had been done by telephone. The editor, who reviewed and approved the story, had visited California only twice (for reasons unrelated to the story about Respondent).

Issue.

Did California have jurisdiction over the Petitioners (the reporter and editor)?

Held.

Yes. Jurisdiction over Petitioners was proper based on the effect of their Florida conduct in California.

Discussion.

Petitioners’ intentional and allegedly libelous conduct was directed at California, where Respondent lived and worked, and where the publication in which the story was published had its largest circulation. Under Worldwide Volkswagen Corp. v. Woodson, Petitioners could have reasonably anticipated being haled into court in California.