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