Young v. New Haven Advocate case brief summary
§ Rules of Law:
o Test based on “intent to direct” activity into the forum state.
o No sufficient minimum contacts = no personal jurisdiction.
o Whether the newspapers and their staff subjected themselves to personal jurisdiction in VA by posting news articles on the internet that allegedly defamed the warden of a VA prison.
§ Standard: Whether the defendant has sufficient minimum contacts with the forum state such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.
o Specific Jurisdiction: Based on conduct connected to the suit.
o General Jurisdiction: General ties to the forum.
§ Specific Jurisdiction?—
(1) Whether the defendant purposefully availed itself of the privileges of conducting activities in the forum state by intentionally directing internet activity at the forum state;
(2) With the manifested intent of engaging in business or other interactions within the State; and
(3) That activity causes injury that gives rise to the potential claim cognizable in that state.
o A person’s act of placing information on the internet is not sufficient by itself to subject that person to personal jurisdiction in each State in which the information is accessed.
§ Something more than posting and accessibility is needed to indicate that the newspapers purposefully directed their activity in a substantial way to the forum state.
§ The newspapers must, through the internet posting, manifest an intent to target and focus on VA readers.
§ The overall content of both websites is decidedly local, and neither newspaper’s website contains advertisements aimed at a VA audience.
§ The websites appears to maintain their websites to serve local readers in Connecticut; the websites are not designed to attract or serve a VA audience.
§ The focus of the articles was the Connecticut prisoner transfer policy and its impact on the transferred prisoners and their families in Connecticut, making Connecticut, not Virginia the focal point of the articles.