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Keeton v. Hustler

From lawbrain.com

Keeton v. Hustler Magazine, Inc., 465 U.S. 770 (1984), is a civil procedure case in which the Supreme Court held that a state has an interest in exercising personal jurisdiction over those who commit torts within its territory, and also extends to actions brought by non-residents.

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Summary of Case Facts

As a New York resident, Keeton's (plaintiff) only connection to New Hampshire was through the circulation of copies of a magazine she assisted in producing. Hustler Magazine, Inc., (Defendant) an Ohio corporation with its principal place of business in California, has a connection to New Hampshire only through the sale of ten to fifteen thousand copies of its magazine each month. Plaintiff claims to have been libeled in five separate issues of defendant’s magazine. Plaintiff brought suit against the defendant in Ohio, which was dismissed because the statute of limitations expired. New Hampshire is the only state in which the statute of limitations for libel actions had not expired. Plaintiff then brought suit in U.S. District Court for the District of New Hampshire. The District court dismissed the case because the Due Process Clause forbade the application of New Hampshire’s long-arm statute in order to acquire personal jurisdiction over defendant. Plaintiff appealed to the Court of Appeals, which affirmed.


Whether New Hampshire has personal jurisdiction over non-resident plaintiff and non-resident defendant, where defendant’s only connection to New Hampshire is the sale of its magazine.

Holding and Law

Yes. The defendant’s regular circulation of magazines in the forum state (New Hampshire) coupled with New Hampshire’s interest in redressing injuries that occur within the state established jurisdiction. Victims of libel may bring suit in any forum where the defendant has minimum contacts. By circulating magazines purposefully throughout New Hampshire, it unavoidably affected persons in the state. Therefore, New Hampshire jurisdiction over a defendant based on those contacts would satisfy the requirement of the Due Process Clause of "minimum contacts" between the defendant and state.

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