Libel Case Jurisdiction
In Calder v. Jones (1984) 465 U.S. 783, a reporter and editor of the National Enquirer challenged California's jurisdiction over them in a libel suit brought by a California resident.
The court held:
"The allegedly libelous story concerned the California activities of a California resident. It impugned the professionalism of an entertainer whose television career was centered in California. The article was drawn from California sources, and the brunt of the harm, in terms both of respondent's emotional distress and the injury to her professional reputation, was suffered in California. In sum, California is the focal point both of the story and of the harm suffered. Jurisdiction over petitioners is therefore proper in California based on the 'effects' of their Florida conduct in California." (Id. at pp. 788-789.)
Further, "Petitioners' intentional, and allegedly tortious, actions were expressly aimed at California. Petitioner South wrote and petitioner Calder edited an article that they knew would have a potentially devastating impact upon respondent. And they knew that the brunt of that injury would be felt by respondent in the State in which she lives and works and in which the National Enquirer has its largest circulation. Under the circumstances, petitioners must 'reasonably anticipate being haled into court there' to answer for the truth of the statements made in their article. " (Calder, supra, 465 U.S. at pp. 789-790.)
Thus, in examining the relationship between "the defendant, the forum, and the litigation" the facts were sufficient to justify jurisdiction. (Id. at p. 788.)