Keeton v. Hustler Magazine
465 U.S. 770 (1984)
- Keeton sued Hustler for libel in New Hampshire. Hustler argued that New Hampshire did not have jurisdiction to hear the case.
- Keeton was a resident of New York, with no connection to New Hampshire, Hustler sold magazines in New Hampshire.
- Keeton chose that forum because it was the only State where her suit would not have been barred by a Statute of Limitations.
- The US Supreme Court found the New Hampshire had jurisdiction.
- The US Supreme Court found that New Hampshire had a substantial interest in helping other States to provide a forum for efficiently litigating all issues and claims.
- The Court found there was jurisdiction even though Keeton had no connection with New Hampshire.
- “We have not to date required a plaintiff to have minimum contacts with the forum State before permitting that State to assert personal jurisdiction over a nonresident defendant. On the contrary, we have upheld the assertion of jurisdiction where such cases were entirely lacking.”
- Btw, for defamation claims, there is a “one-publication rule,” meaning that if there is one publication in the State that defames you, that Court will adjudicate the damages for defamation in all States. This way you don’t have to sue in every single State.
- So even though Keeton couldn’t sue in other States, she could still get damages for defamation in those States by winning in New Hampshire!