March 18, 2020

Keeton v. Hustler - 465 U.S. 770, 104 S.Ct. 1473, 79 L.Ed.2d 790 (1984) - Supreme Court of the United States

FACTS: Keeton lived in New York. Hustler is an OH corporation w/ principal place of business in CA. Hustler's contact w/ NH consist of 10-15 thousand copies of the magazine sold there each month. Keeton's contact w/ NH consist of her being libeled there and her name being mentioned in several places in a magazine that she helps produce. She had filed suit in OH but the statute of limitations had run out so she re-filed in NH which has a 6 year statutes of limitations. NH applied the "single publication rule" which entitled the plaintiff to win damages for the libel published in all the states. 

ISSUE: Did NH have proper jurisdiction? 

HOLDING: Yes 

RATIONALE: Plaintiff is not required to have "minimum contacts." In regards to the issues of the 6 year statute of limitations "the issue is personal jurisdiction not choice of law." (233) 

DISPOSITION: Affirmed