Young v. New Haven Advocate [1]

The warden of a Virginia prison sued two Connecticut newspapers for libel in a Virginia court, asserting that they published defamatory articles about him on their websites. In his complaint [2], Young asserted the newspapers implied he was racist and that he encouraged guards to abuse inmates. Compl. [2] ¶ 7.

On Oct. 4, 2000, the New Haven Advocate and the Hartford Courant filed motions to dismiss the suit on the grounds that a Virginia court cannot exercise personal jurisdiction over Connecticut newspapers. The United States District Court for the Western District of Virginia denied the motion, stating the court could exercise jurisdiciton under Virginia law because the "defendants' Connecticut-based Internet activities constituted an act leading to an injury to the plaintiff in Virginia."

The newspapers appealed to the United States Court of Appeals for the Fourth Circuit, which reversed the lower court's decision. In its opinion [3], the court said the Connecticut newspapers could not constitutionally be subject to jurisdiction in a Virginia court because "they did not manifest an intent to aim their websites or the posted articles at a Virginia audience."

The United States Supreme Court declined to hear Young's appeal on May 19, 2003.