Calder v. Jones | |
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Argued November 8, 1983 Decided March 20, 1984 |
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Full case name | Calder, et al. v. Shirley Jones |
Citations | 465 U.S. 783 (more)
104 S. Ct. 1482; 79 L. Ed. 2d 804; 1984 U.S. LEXIS 41; 52 U.S.L.W. 4349; 10 Media L. Rep. 1401
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Prior history | Appeal from the Court of Appeal of California, Second Appellate District |
Holding | |
A state's courts could assert personal jurisdiction over the author or editor of a libelous article, where the author or editor knew that the article would be widely circulated in the state where the subject of the article would be injured by the libelous assertion. | |
Court membership | |
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Case opinions | |
Majority | Rehnquist, joined by unanimous |
Laws applied | |
U.S. Const. amend. XIV |
Calder v. Jones, 465 U.S. 783 (1984), was a case in which the United States Supreme Court held that a court within a state could assert personal jurisdiction over the author and editor of a national magazine which published an allegedly libelous article about a resident of that state, and where the magazine had wide circulation in that state.
The plaintiff, actress Shirley Jones (represented by Paul Ablon), sued the defendants, the National Enquirer, its distributor, the writer of the article, and Calder, the editor-in-chief of the magazine, over an October 9, 1979 article in which the Enquirer alleged that Jones was an alcoholic. Jones lived in California, and although the Enquirer article had been written and edited in Florida, Jones filed her lawsuit in a California state court. Jones asserted that the court had jurisdiction based on the large circulation Enquirer enjoyed in California - selling over 600,000 copies each week out of a total national circulation of about 5,000,000 copies per week.
The publisher and the distributor did not object to jurisdiction in California. The trial court dismissed the claim as to the author and editor on the grounds that it lacked personal jurisdiction over the defendants, basing this finding on First Amendment concerns that permitting jurisdiction in such cases would chill free speech. The California Court of Appeal reversed, and the Supreme Court of California affirmed the appellate court's ruling. Calder appealed, as did the writer of the article, contending that the writer and editor of a magazine article were like welders of a boiler part. In such a case, although the manufacturer of the product could be held liable in another state where the product caused an injury, a worker who had neither a stake in the distribution nor any control over it would not be held liable in that state.