Young v New Haven Advocate

Fact pattern and procedural history

Plaintiff Young, a Virginia jailer, sued the New Haven Advocate in the Western District of Virginia for libel on the basis of articles it published about a Connecticut incarceration program. The program placed Connecticut inmates in Virginia prisons, and the articles alleged that the practice was harmful to inmates and their families, including statements which implied Young was racist. Defendant made a special appearance to contest jurisdiction under the federal rules of civil procedure.

Questions of law

If members of a jurisdiction read articles on the internet which defame a member of that jurisdiction, but the articles were published outside of the state, what is required for that jurisdiction to assert personal jurisdiction?

Finding

The court held that the defendants’ articles concerned the Connecticut incarceration policy and its impact on Connecticut inmates and Connecticut families. The court determined that the articles, despite any adverse impact they might have had on the plaintiff, were not directed into the jurisdiction of Virginia and accordingly did not give rise to personal jurisdiction.

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