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Young v. New Haven Advocate

United States Court of Appeals for the Fourth Circuit
315 F.3d 256 (2002)



Young (plaintiff), a Virginia prison warden, sued newspapers the New Haven Advocate (the Advocate) and the Hartford Courant (the Courant), two editors, and two reporters (defendants) for defamation in the United States District Court for the Western District of Virginia. Several articles about a Connecticut policy transferring inmates to Virginia prisons, which were published online, implied that Young was racist and encouraged abusing prisoners. The Advocate is a New Haven newspaper with no subscribers in Virginia. The Courant is a Hartford newspaper with eight subscribers in Virginia. Neither newspaper has offices or solicits business in Virginia. The reporters never travelled to Virginia and do not live, work, or have property there, though they did make phone calls to Virginia to conduct interviews. Both newspapers’ websites are geared toward Connecticut residents and make no mention of Virginia. The defendants moved to dismiss for lack of personal jurisdiction. The court denied the motion, asserting that jurisdiction was proper under Virginia’s long-arm statute and constitutional due to the defendants’ online activities. The defendants filed an interlocutory appeal to the United States Court of Appeals for the Fourth Circuit.

Rule of Law


Holding and Reasoning (Michael, J.)

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