## Facts

- Shirley Jones, a California resident whose professional reputation and work were centered in California, sued for libel based on an article published in the National Enquirer.
- The article claimed Jones was an alcoholic and that her drinking impaired her professional performance.
- The National Enquirer was a national weekly publication with its largest circulation in California (about 600,000 copies weekly).
- The reporter (South) wrote the story in Florida; the editor (Calder) reviewed and edited it in Florida for publication.
- The story concerned Jones’s California-based activities, relied on California sources, and foreseeably impacted her reputation primarily in California.
- Jones filed suit in California state court against the publisher, its distributor, and the reporter and editor.
- South and Calder specially appeared and moved to quash service, arguing they lacked sufficient contacts with California and were merely employees acting in Florida.

## Issues

1. Whether the Due Process Clause permits California courts to exercise specific personal jurisdiction over nonresident writer and editor for an allegedly libelous article written and edited outside California but intentionally causing reputational injury in California.
2. Whether First Amendment concerns alter the due process analysis for personal jurisdiction in a libel action.

## Decision

- The Supreme Court unanimously held that California’s exercise of personal jurisdiction over South and Calder was constitutional.
- The Court found sufficient minimum contacts because petitioners’ intentional conduct was expressly aimed at California and allegedly caused harm there.
- The Court rejected the argument that petitioners’ status as employees insulated them from jurisdiction, emphasizing that each defendant’s own contacts must be assessed.
- The Court treated First Amendment concerns as irrelevant to the jurisdictional inquiry, leaving speech protections to be addressed on the merits.

## Legal Principles

- A state may exercise specific personal jurisdiction when the defendant has minimum contacts such that suit does not offend traditional notions of fair play and substantial justice.
- The jurisdictional inquiry focuses on the relationship among the defendant, the forum, and the litigation.
- For intentional torts, jurisdiction may be proper where the defendant’s conduct is expressly aimed at the forum and the defendant knows the brunt of the injury will be felt there (the “effects” basis for specific jurisdiction).
- Employee status does not bar personal jurisdiction; courts evaluate each individual defendant’s purposeful forum-directed conduct rather than imputing the employer’s contacts.
- First Amendment considerations do not modify the due process test for personal jurisdiction; they are addressed through substantive defamation standards and defenses.

## Conclusion

California could exercise specific personal jurisdiction over the Florida-based reporter and editor because they intentionally created and approved an article targeting a California resident, knew it would be widely circulated in California, and could foresee that the principal reputational injury would be suffered there.


Calder v. Jones, 465 U.S. 783 (1984)