Legros v. Irving

In Legros v. Irving (38 AD2d 53 [1st Dept 1971]), the first case in which a New York appellate court upheld jurisdiction over a non-domiciliary defendant against whom a defamation claim had been raised, the defendant had performed substantial work in New York on the book in which the alleged libel was published; he had negotiated his contract with the publisher in New York; and the book had been printed in New York. In Legros v. Irving, New York jurisdiction was upheld as it was "clear that virtually all the work attendant upon publication of the allegedly defamatory book occurred in New York. The book was in part researched in this State by defendant . . . ; negotiations with McGraw-Hill [the publisher and distributer] took place in New York; the contract with McGraw-Hill was executed in New York and the book was printed in New York" (38 AD2d at 56).