465 U.S. 770 (1984)
Keeton v. Hustler Magazine, Inc.
Does a state court have personal jurisdiction over a non-resident defendant in a libel case when the defendant's publication is widely circulated in the state and causes harm to the plaintiff's reputation?
The Supreme Court held that a state court may exercise personal jurisdiction over a non-resident defendant if the defendant has sufficient minimum contacts with the forum state, such that the exercise of jurisdiction does not offend traditional notions of fair play and substantial justice. In the context of libel cases, the court recognized that the circulation of a publication in a state can establish the necessary contacts for jurisdiction.
The Supreme Court ruled in favor of Keeton, affirming the New Hampshire Supreme Court's decision that the state had personal jurisdiction over Hustler Magazine. The Court found that Hustler's nationwide distribution of its magazine, which included the allegedly defamatory article, constituted sufficient minimum contacts with New Hampshire. The Court reasoned that by targeting a national audience and causing harm to a resident of New Hampshire, Hustler could reasonably anticipate being haled into court in that state.
Keeton v. Hustler Magazine is a pivotal case for law students as it delineates the boundaries of personal jurisdiction in the context of libel and defamation claims. The ruling has had lasting implications on how courts evaluate jurisdictional issues, particularly concerning media defendants who operate across state lines. This case has been cited in numerous subsequent decisions, reinforcing the principle that the distribution of a publication can establish sufficient contacts for jurisdiction.