Keeton sued Hustler for libel
in New Hampshire. Hustler argued that New Hampshire did not have jurisdiction to hear the case.
Keeton was a resident of New
York, with no connection to New Hampshire, Hustler sold magazines in New
Keeton chose that forum
because it was the only State where her suit would not have been barred
by a Statute of Limitations.
The US Supreme Court found the
New Hampshire had jurisdiction.
The US Supreme Court found
that New Hampshire had a substantial interest in helping other States to
provide a forum for efficiently litigating all issues and claims.
The Court found there was jurisdiction even though Keeton had no connection with New
"We have not to date
required a plaintiff to have minimum contacts with the forum State
before permitting that State to assert personal jurisdiction over a
nonresident defendant. On the contrary, we have upheld the assertion of
jurisdiction where such cases were entirely lacking."
Btw, for defamation claims,
there is a "one-publication rule," meaning that if there is one
publication in the State that defames you, that Court will adjudicate the
damages for defamation in all States. This way you don't have to sue in
every single State.
So even though Keeton
couldn't sue in other States, she could still get damages for defamation
in those States by winning in New Hampshire!