Calder v. Jones
SCOTUS - 1984 (465 U.S. 783)
- P (CA) brought suit in CA Superior Court against Ds claiming that she had been libeled in an article written and edited by Ds in FL.
- Ds are employed by Enquirer, FL corporation with its largest circulation in CA.
- D South is reporter with Enquirer, travels frequently to FL on business.
- D Calder is president and editor of Enquirer. He has little/no ties to FL.
- Superior Court of CA ruled for D. (Said that the actions of Ds would normally by sufficient for jurisdiction but court was afraid of the effects of having reporters haled to remote jurisdictions just because their stories could be read there)
- Court of Appeals of CA reversed, ruled for P.
- SCOTUS affirmed, ruled for P, jurisdiction valid.
- Can a state exercise jurisdiction over a D if the D aimed "bad actions" towards that forum state?
- A state can exercise jurisdiction over a D based on the "effects test" - a state has power to exercise personal jurisdiction over a party who causes effects in a state by an act done elsewhere with respect to any cause of action arising from these effects.
- The alleged libelous story concerned the activities of a CA resident and hurt the career of an entertainer who worked in CA. The article was drawn from CA sources, and the brunt of the harm was suffered in CA. CA was the focal point of both the harm and the story.
- The negligence was not untargeted; the actions were aimed at CA and at the P.
- An individual injured in CA doesn't need to go to FL to sue people in FL who knowingly caused harm in CA.
- Made use of the "effects test".
- The "effects test" says that a state has power to exercise personal jurisdiction over a party who causes effects in a state by an act done elsewhere with respect to any cause of action arising from these effects.
- Court shouldn't appoint the article as agent for service of process.
- This case will have larger implications with cases involving the internet.
- Effects test - must know that the tortuous action was purposefully aimed at a particular state
- The Calder effects test will allow personal jurisdiction over a party whose…
- Conduct was expressly aimed at the forum state,
- Knowing that the harmful effects would be felt primarily there
- And that the defendants would "reasonably anticipate being haled into court there".