Calder v. Jones, 465 U.S. 783, 1984

NAME:
Calder v. Jones, 465 U.S. 783, 1984

FACTS:
· Respondent (“R”), a resident of California, brought this suit against the National Enquirer, Inc., its local distributing company, & petitioners (“P”) for libel, invasion of privacy, & IIED. The article at issue questioned the professionalism of the R stating that the she drank so heavily preventing her from fulfilling her professional obligations.
· P South, a reporter employed by the Enquirer & a resident of Florida, wrote the first draft of the challenged article, & his byline appeared on it. Most of his research for the article was done in Florida w/ the aid of sources located in California. Aside from his frequent trips & phone calls, P South has no other relevant contacts w/ California.
· P Calder, also a Florida resident & president/editor of the Enquirer, has only been to California twice; once on a pleasure trip & the other to testify in an unrelated trial & has no other relevant contacts w/ California. He reviewed/approved the initial evaluation of the subject of the article & edited it in its final form.

PROCEDURE:
Originally the suit was filed in California Superior Court, but was dismissed on the grounds that First Amendment concerns weighed against an assertion of jurisdiction otherwise proper under the Due Process Clause. The California Court of Appeals reversed, stating that a valid basis for jurisdiction did exist on the theory that petitioners intended to, & did, cause tortuous injury to R in California.

ISSUE:
Can R, a California resident, bring suit against a Florida corporation’s employees (Florida residents) in a California court for a claim of libel by asserting that California has personal jurisdiction over Florida residents?

HOLDING:
YES. California is the focal point of both the story & the harm suffered & therefore, jurisdiction over P is proper in California based on the “effects” of their Florida conduct in California.

REASONING:
· California’s “long-arm” statute permits an assertion of jurisdiction over a nonresident Δ whenever permitted by the state & federal Constitutions. –Section 410.10
· Therefore, turning to the Constitution, the Due Process Clause of the 14th Amendment permits personal jurisdiction over a Δ in any state w/ which the Δ has “certain minimum contacts…such that the maintenance of the suit does not offend ‘traditional notions of fair play and substantial justice.’ –Milliken v. Meyer, 311 U.S. 457, 463
· So, in judging minimum contacts, a court properly focuses on the “the relationship among the Δ, the forum, & the litigation.” –Shaffer v. Heitner, 433 U.S. 186, 204
· This follows that Ps’ wrote/edited an article that they knew would have a potentially devastating impact upon R. Furthermore, Ps’ knew that the brunt of that injury would be felt by R in the state in which she lives/works & in which the National Enquirer has its largest circulation.
· Under the circumstances, Ps must “reasonably anticipate being haled into court there” to answer for the truth of the statements made in their article. –World-Wide Volkswagen Corp. v. Woodson
· Finally, an individual injured in California need not go to Florida to seek redress from persons who, though remaining in Florida, knowingly cause the injury in California.

DISPOSITION:
Judgment of the California Court of Appeal is Affirmed

DISSENT:
None

EVALUATION:
The court properly held that California courts have personal jurisdiction over a non-resident where the non-resident is the primary participant in an alleged wrongdoing intentionally directed at a California resident. R was negatively affected by the intentional libel of the P & its effects were felt in California, where R lived.

SYNTHESIS:
Jurisdiction over non-resident Δ is permitted where Δ has min. contacts such that maintenance of the suit doesn’t offend ‘traditional notions of fair play & substantial justice,’ –Milliken v. Meyer. In judging min. contacts, the court must focus on the relationship among the Δ, forum, & litigation.