CaseCast™ – "What you need to know"
Brief Fact Summary. Respondent, Shirley Jones, brought a libel suit in a California state court against Petitioners, Calder et al. Petitioners South and Calder are Florida residents who argue that California courts lack personal jurisdiction over them.
Synopsis of Rule of Law. A state has personal jurisdiction over any party whose actions intentionally reach another party in the state and are the basis for the cause of action.
We have already declined in other contexts to grant special procedural protections to defendants in libel and defamation actions in addition to the constitutional protections embodied in the substantive laws.View Full Point of Law
Issue. The issue is whether California has personal jurisdiction over South and Calder through their targeting of Respondent with this article.
Held. The United States Supreme Court held that California had personal jurisdiction over Petitioners. The first step in the analysis is to determine the focal point of the harm suffered, and that was in California. The Court then determined that Petitioners’ actions intentionally aimed at a California resident, and the injuries suffered would be in that state.
Discussion. Petitioners argued that, because they were merely employees of the libelous newspaper, their case was analogous to a welder who works on a boiler in Florida that subsequently explodes in California. The Court distinguishes this by noting that unlike the welder they intentionally targeted the California contact.