Calder v. Jones

Questions Presented

1. Whether California could exercise personal jurisdiction over Florida residents who intentionally wrote and edited an allegedly tortious article directed at a California resident and causing the brunt of the alleged injury in California.
2. Whether First Amendment concerns should be weighed against otherwise proper personal jurisdiction in a libel or defamation action.
3. Whether the Supreme Court had appellate jurisdiction over the state-court judgment and, if not, could treat the jurisdictional statement as a petition for certiorari

Factual background

Shirley Jones, a California resident and entertainer whose professional activities were centered in California, sued Florida-based Enquirer reporter Robert South and editor William Calder over an allegedly libelous article. South wrote the first draft after conducting research in Florida and communicating with California sources; Calder reviewed, edited, approved, and declined to print a requested retraction. The article was published nationally, with approximately 600,000 copies sold in California, and the brunt of the alleged reputational and emotional injury was suffered there.

Procedural history

Jones sued petitioners and others in California Superior Court for libel, invasion of privacy, and intentional infliction of emotional harm based on an article written and edited in Florida. The Superior Court granted petitioners' motion to quash service, concluding that First Amendment concerns weighed against jurisdiction. The California Court of Appeal reversed, holding that petitioners' intentional conduct directed at California supported jurisdiction and that First Amendment considerations did not alter the jurisdictional analysis. The Supreme Court affirmed.