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Calder v. Jones

(1984)

Supreme Court of the United States - 465 U.S. 783, 104 S. Ct. 1482

tl;dr:

A libelous article intentionally directed towards a CA actress allows CA to exercise personal jurisdiction over the non-resident article writers.

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Case Summary

In 1984, the US Supreme Court decided on Calder v. Jones, a case about personal jurisdiction involving an actress (Jones), and a magazine editor and an article writer (Calder and South). The article, written and edited in Florida, accused Jones of being an alcoholic, causing harm to her reputation in California where she lived and worked. Jones sued the two in California for libel, but Calder and South argued that they had no minimum contacts with the state and shouldn't be under its jurisdiction.

The Supreme Court upheld the California Court of Appeal's decision, allowing jurisdiction over the two defendants. The Court applied the "effects test," which states that a person can be subject to a state's jurisdiction if they intentionally cause harm in that state, even from outside of it. The justices found that the defendants knew the article would harm Jones, and that the damage would mainly happen in California.

This case established a new basis for personal jurisdiction over out-of-state defendants based on their intentional actions in the forum state. The Court recognized that modern communication allows for causing harm from afar, and that those causing it shouldn't avoid liability. It emphasized fairness and justice in personal jurisdiction, and adopted a flexible approach to applying the effects test.

This case introduced the the "Calder effects test" which states that a defendant has deliberately directed conduct at the state of suit if they (1) commit an intentional act, (2) expressly aimed at the state of suit, that (3) causes harm the defendant knew was likely to be suffered in the state of suit.

ICRAIssue, Conclusion, Rule, Analysis for Calder v. Jones

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Facts & HoldingCalder v. Jones case brief facts & holding

Facts:Jones is a resident of CA, and works as a...

Holding:The allegedly libelous article was drawn from CA sources, and...

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Calder v. Jones | Case Brief DeepDive
Majority opinion, author: Justice Rehnquist
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The National Enquirer, a Florida corporation, was sued for libel by a California resident based on an article published in California. The defendants argued that they could not be sued in California because they had no significant contacts with the state. The California Court of Appeal reversed the lower court's decision, stating that the defendants could be sued in California because they intended to and did cause injury to the plaintiff in California. The Supreme Court of the United States held that personal jurisdiction over a defendant is allowed in any state where the defendant has "certain minimum contacts" that do not offend traditional notions of fair play and substantial justice. The court considers the relationship among the defendant, the forum, and the litigation when judging minimum contacts. In cases where the plaintiff is the focus of the activities of the defendants out of which the suit arises, jurisdiction may be permitted.

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