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Baldwin v. Fischer-Smith

315 S.W.3d 389 (2010)

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Baldwin v. Fischer-Smith

Missouri Court of Appeals
315 S.W.3d 389 (2010)

MP

Facts

Dog-breeding kennel owners from Missouri (plaintiffs) sued Arizona and Pennsylvania website owners (defendants) in Missouri for libel. The kennel owners alleged that they were defamed when the website owners used their website—that anyone with internet access could view—to malign and damage the kennel owners and the kennel owners’ business. The website owners contested the Missouri court’s personal jurisdiction over them, and the trial court dismissed the action. The trial court found that the website owners committed libel in Missouri but lacked sufficient minimum contacts with Missouri under the Due Process Clause for long-arm jurisdiction. The kennel owners appealed and urged the appellate court to find jurisdiction over the nonresident defendants based on the effects test from Calder v. Jones, 465 U.S. 783 (1984).

Rule of Law

Issue

Holding and Reasoning (Scott, C.J.)

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