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.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 724,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 724,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,600 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.