Young v. New Haven Advocate

Young (plaintiff), a Virginia prison warden, sued two Connecticut newspapers and several of their staff (defendants) for defamation in Virginia federal court over online articles implying he was racist and encouraged prisoner abuse. Neither paper had offices, solicited business, or geared its website content toward Virginia; one had zero Virginia subscribers, the other only eight, and reporters had made phone calls into Virginia but never traveled there. The district court found jurisdiction proper based on the defendants' online activity, and the defendants took an interlocutory appeal.

Whether a court may exercise personal jurisdiction over a party based solely on internet content that is accessible within the state.