## Facts

- Stanley K. Young, warden of Wallens Ridge State Prison in Virginia, oversaw a facility that housed approximately 500 Connecticut inmates transferred under a contract responding to Connecticut prison overcrowding.
- The transfer policy triggered political debate and protests in Connecticut and became the subject of reporting by two Connecticut newspapers: the New Haven Advocate and the Hartford Courant.
- The Advocate published a story describing allegedly harsh conditions at Wallens Ridge and noting litigation by Connecticut inmates alleging inadequate hygiene and medical care and denial of religious privileges.
- The Courant published a column criticizing the transfer policy and conditions at Wallens Ridge.
- Young alleged the online versions of these publications defamed him by implying racism and encouragement of inmate abuse.
- The newspapers were Connecticut-focused: the Advocate had no Virginia subscribers; the Courant had eight Virginia mail subscribers; neither had offices, employees, or subscription solicitation in Virginia.
- The reporters did not travel to Virginia; their Virginia contacts were limited to telephone interviews with Virginia residents.
- Young filed a defamation action in federal court in the Western District of Virginia, asserting reputational injury in Virginia from the Internet postings.

## Issues

1. Whether Virginia courts could constitutionally exercise specific personal jurisdiction over out-of-state newspapers and journalists based on allegedly defamatory articles posted to Connecticut-oriented websites accessible in Virginia.
2. Whether Internet accessibility and foreseeable in-forum reputational injury satisfy due process absent intentional targeting of the forum state.

## Decision

- The Fourth Circuit reversed the district court’s denial of the motion to dismiss for lack of personal jurisdiction.
- The court held Virginia could not constitutionally exercise specific personal jurisdiction over the Connecticut newspaper defendants.
- The case was remanded with instructions consistent with dismissal for lack of personal jurisdiction.

## Legal Principles

- Specific personal jurisdiction based on Internet activity requires more than global website accessibility; due process demands purposeful direction of conduct toward the forum.
- Under the Fourth Circuit’s Internet-jurisdiction standard, jurisdiction may be exercised only if the defendant: (1) directs electronic activity into the state, (2) with manifested intent to engage in business or other interactions within the state, and (3) that activity creates a potential cause of action cognizable in the state’s courts.
- In defamation cases involving online publication, in-forum injury to a plaintiff does not alone establish jurisdiction; the defendant must have expressly aimed the publication at the forum state’s audience.
- Courts evaluate the website’s overall orientation and the publication’s focal point; content centered on another state’s policy debate and readership does not constitute targeting of the forum merely because the subject is located there.

## Conclusion

Because the newspapers’ websites and the challenged publications were aimed at Connecticut readers and Connecticut public debate, and not at a Virginia audience, Virginia lacked specific personal jurisdiction despite the articles’ availability in Virginia and the plaintiff’s claimed reputational harm there.


Young v. New Haven Advocate, 315 F.3d 256 (4th Cir. 2002)