Calder v. Jones (1983)
- Docket
- 82-1401
- Decided
- 1983-01-01
Summary
Question: Did Calder and South have sufficient contacts with the state of California to give California state courts personal jurisdiction over Jones’ claim of libel? Conclusion: Yes. In a unanimous opinion written by Justice William Rehnquist, the Court held that Calder's and South’s contacts with California were sufficiently strong to give California state courts jurisdiction over Jones’ libel claim. Justice Rehnquist wrote that the Due Process Clause of the Fourteenth Amendment only permits personal jurisdiction when a defendant has certain minimum contacts with a state such that maintenance of the suit does not offend traditional notions of fair play and substantial justice. Looking to the facts of Jones’ claim, Justice Rehnquist emphasized that the allegedly libelous story concerned the California activities of a California resident, and that Jones’ television career was based in California. In addition, the alleged injury to Jones’ career was suffered in California. Thus, jurisdiction was proper because of the effects of Calder and South’s Florida activities in California. Unlike a welder who helps create a boiler in one state that is sold in another state and that subsequently malfunctions, Calder and South allegedly intentionally directed their actions at California. Justice Rehnquist noted that courts must evaluate each defendants’ contacts with a given state to determine if they’re sufficient, even if defendants work for the same organization. He rejected Calder and South’s argument that extending jurisdiction over writers and editors in remote states would have a chilling effect on speech; First Amendment concerns about that effect are already taken into account in the constitutional limits on the substantive law of libel.