Calder v. Jones Case Brief

Why is the case important?

Respondent, Shirley Jones, brought a libel suit in a California state court against Petitioners, Calder et al. Petitioners South and Calder are Florida residents who argue that California courts lack personal jurisdiction over them.

Facts of the case

“Shirley Jones was a professional actress and California resident whose television career was also based in California. Marty Ingels, her husband, was also a professional entertainer. On October 9, 1979, the National Enquirer published an article about Jones. John South wrote the first draft of the article, and his byline appeared on it. Shortly before publication, South called Ingels to read him the article and elicit his comments on it. Ian Calder, the president and editor of the Enquirer, declined to print a retraction.National Enquirer, Inc. was a corporation that published a national newspaper with a total circulation of over five million, 600,000 copies of which were sold in California. John South was a reporter for the Enquirer. He was a resident of Florida, but frequently travelled to California on business. Ian Calder was a Florida resident and he exerted close control over the functions of the Enquirer

  • he had traveled to California only twice and had no other relevant contacts with that state.Jones filed an action in California state court against Calder and South, alleging that the article was untrue, libelous, and that it damaged their reputations and good names. The superior court ruled that although the injury occurred in California, it lacked personal jurisdiction over the claim because of the potential chilling effect from requiring editors and reporters to appear in remote jurisdictions. The California Court of Appeals reversed because the defendants intended to cause tortious injury to Jones and Ingels in California. A timely petition for appeal to the Supreme Court of California was denied, but the Supreme Court of the United States treated it as a petition for a writ of certiorari, granting review.”

    Question

    The issue is whether California has personal jurisdiction over South and Calder through their targeting of Respondent with this article.

    Answer

    The United States Supreme Court held that California had personal jurisdiction over Petitioners. The first step in the analysis is to determine the focal point of the harm suffered, and that was in California. The Court then determined that Petitioners’ actions intentionally aimed at a California resident, and the injuries suffered would be in that state.

    Conclusion

    The Supreme Court held that jurisdiction was proper based upon the effects of their intentional conduct in California. Respondent’s career was centered in California, the article was drawn from California sources, and the harm was suffered in California. The Supreme Court noted that petitioners were not charged with untargeted negligence, but rather their intentional, and allegedly tortious, actions were expressly aimed at California, and under the circumstances, petitioners must have reasonably anticipated being sued there. The Supreme Court held that petitioners’ status as employees did not shield them from jurisdiction, because their individual contacts with California were sufficient.

    • Case Brief: 1984
    • Petitioner: Ian Calder, John South
    • Respondent: Shirley Jones
    • Decided by: Burger Court

    Citation: 465 US 783 (1984)
    Argued: Nov 8, 1983
    Decided: Mar 20, 1984
    Granted Apr 18, 1983