Keeton v. Hustler Magazine, Inc. (1983)
- Docket
- 82-485
- Decided
- 1983-01-01
Summary
Question: Was Hustler's circulation of magazines within the forum state of New Hampshire alone sufficient, without regard to the depth of plaintiff's contacts or the amount of plaintiff's damages caused in New Hampshire, to support an assertion of personal jurisdiction in a libel action based upon the contents of the magazine? Conclusion: Yes. Hustler's regular circulation of magazines in New Hampshire is sufficient to support an assertion of personal jurisdiction in a libel action based on the contents of the magazine. In analyzing whether there are sufficient minimum contacts to permit personal jurisdiction under the Fourteenth Amendment, a court should focus on the relationship among the defendant, the forum, and the litigation. Hustler has continuously and deliberately exploited the New Hampshire market and therefore it must reasonably anticipate being hauled into court there. Keeton did not need to have minimum contacts with the forum state in order for that state to have asserted personal jurisdiction over Hustler. New Hampshire had a sufficient interest in adjudicating the dispute. Moreover, even though most of the harm done to Keeton occurred outside New Hampshire, the same would be true in most libel cases brought anywhere other than plaintiff's state of domicile.