Jackson v. California Newspapers Partnership
United States District Court for the Northern District of Illinois
406 F. Supp. 2d 893 (2005)
Mohr (defendant), a sports editor for a California newspaper, wrote an article quoting a speaker as saying Bo Jackson (plaintiff) lost his hip to steroid abuse; the article ran online and in print. The paper had about 65,000 print subscribers, only one in Illinois, no internet subscribers there, and a website with almost no interactivity for outsiders (local contact numbers and information only). Jackson sued the reporter and the paper's owners (defendants) in Illinois state court for defamation and related claims; the defendants removed to federal court and moved to dismiss for lack of personal jurisdiction.
Whether maintaining a website with almost no interactivity toward out-of-state users is sufficient to create personal jurisdiction over a defendant with no other meaningful contacts to the forum state.