Calder v. Jones

Facts

Shirley Jones lived and worked in California. She was an entertainer whose television career was centered there. The National Enquirer, a Florida corporation with its principal place of business in Florida, ran an article about her in its October 9, 1979, issue. She claimed it libeled her. The article alleged that she drank so heavily that she could not fulfill her professional obligations. The Enquirer publishes a national weekly newspaper with a total circulation of over 5 million. About 600,000 copies were sold in California, almost twice the level of the next highest State. South, a Florida resident who frequently traveled to California on business, was a reporter for the Enquirer. He wrote the first draft, and his byline appeared on the article. He did most of his research in Florida, using phone calls to sources in California. Shortly before publication he phoned Jones's home and read a draft to her husband. Calder, also a Florida resident, was the Enquirer's president and editor. He had been to California only twice, once on a pleasure trip before publication and once afterward to testify in an unrelated trial. He approved the initial evaluation of the subject, edited the article in its final form, and declined to print a retraction Jones requested. The article was drawn from California sources, and the brunt of the harm was suffered in California.

Issues

1. Does the Due Process Clause permit a California court to exercise personal jurisdiction over a Florida reporter and a Florida editor who wrote and edited an article about a California resident's California activities, when it was published in a paper widely sold in California?
2. Do First Amendment concerns for reporters and editors enter into the personal jurisdiction analysis in a libel suit?

Holding

California may exercise jurisdiction over South and Calder because their intentional conduct in Florida was calculated to cause injury to Jones in California. Their status as employees does not insulate them, and First Amendment concerns do not enter the jurisdictional analysis.