## Facts

- Vincent E. “Bo” Jackson, an Illinois resident and former professional athlete, sued a California newspaper entity and related corporate and individual defendants for defamation, invasion of privacy, and intentional infliction of emotional distress.
- The claims arose from a sports editor’s article reporting on a California forum about diet, exercise, and steroid use.
- The article attributed to the forum speaker a statement that “Bo Jackson lost his hip because of anabolic abuse.”
- The article was posted on the newspaper’s website the night of the forum and printed in the next day’s edition.
- The forum speaker later submitted a sworn affidavit stating she never mentioned Jackson and never made the quoted statement.
- The newspaper was a local California publication with about 65,000 print subscribers; only one subscriber resided in Illinois, and there were no Illinois subscribers to the electronic version.
- The website’s out-of-state interactivity was minimal and oriented toward a local California audience.
- Defendants removed the case to federal court on diversity grounds and moved to dismiss for lack of personal jurisdiction.

## Issues

1. Whether Illinois courts could exercise general personal jurisdiction over the California-based defendants based on the newspaper’s circulation and operation of a website accessible in Illinois.
2. Whether Illinois courts could exercise specific personal jurisdiction because the allegedly defamatory article was available online and Jackson allegedly suffered injury in Illinois.

## Decision

- The court granted defendants’ motion to dismiss under Rule 12(b)(2) for lack of personal jurisdiction.
- The court held it lacked general jurisdiction because defendants did not have continuous and systematic contacts with Illinois; negligible Illinois circulation and a website’s mere accessibility were insufficient.
- The court held it lacked specific jurisdiction because defendants did not purposefully direct the publication or online posting at Illinois; the article concerned a California event for a California audience.
- The court did not reach the merits of the tort claims and did not decide the alternative request to transfer venue.

## Legal Principles

- In a diversity case, personal jurisdiction is assessed under the forum state’s long-arm statute as constrained by federal due process; the core inquiry is whether defendants have minimum contacts such that jurisdiction is consistent with fair play and substantial justice.
- General jurisdiction requires continuous and systematic forum contacts; operating a website, without more, does not create general jurisdiction in every state where it can be accessed.
- Specific jurisdiction requires purposeful direction or purposeful availment; a plaintiff’s in-forum injury alone does not establish jurisdiction over an out-of-state publisher.
- For media and intentional-tort claims, the forum must be a focal point of the challenged conduct and publication; a local publication about a local event is not “aimed” at the plaintiff’s home state merely because the plaintiff resides there.
- In Internet cases, jurisdiction depends in part on the nature and quality of a defendant’s online commercial interactivity; largely passive or low-interactivity sites generally do not support jurisdiction in a non-targeted forum.

## Conclusion

The court dismissed the suit for lack of personal jurisdiction, holding that a California newspaper’s local reporting and minimally interactive website—despite being accessible in Illinois and allegedly causing injury there—did not amount to continuous Illinois contacts or purposeful direction of the publication toward Illinois.


Jackson v. California Newspapers P'ship, 406 F. Supp. 2d 893 (N.D. Ill. 2005)