Keeton v. Hustler Magazine, Inc.

Kathy Keeton (plaintiff), a New York resident, sued Hustler Magazine (defendant) and others for libel in federal district court in New Hampshire based on diversity jurisdiction, alleging libel in five issues published in 1975-76. Keeton had no contacts with New Hampshire other than helping produce the magazine. Hustler was an Ohio corporation headquartered in California, but sold 10,000 to 15,000 copies per month in New Hampshire. The district court dismissed for lack of personal jurisdiction, and the court of appeals affirmed, reasoning Keeton lacked sufficient contacts with New Hampshire and emphasizing that New Hampshire's unusually long six-year libel statute of limitations was the only reason the suit could still be brought there, while the "single publication rule" would let Keeton recover damages for harm suffered in all fifty states if she won. Keeton petitioned for certiorari.