Griffis v. Luban - 646 N.W.2d 527 (Minn. 2002)

Rule:

The Calder effects test is not satisfied by the mere allegation that the plaintiff feels the effect of the defendant's conduct in the forum because the plaintiff is located there. As interpreted by the United States Third Circuit Court, the test requires the plaintiff to show that: (1) the defendant committed an intentional tort; (2) the plaintiff felt the brunt of the harm caused by that tort in the forum such that the forum state was the focal point of the plaintiff's injury; and (3) the defendant expressly aimed the tortious conduct at the forum such that the forum state was the focal point of the tortious activity. To satisfy the third prong, the plaintiff must show that the defendant knows that the plaintiff will suffer the brunt of the harm caused by the tortious conduct in the forum, and point to specific activity indicating that the defendant expressly aims its tortious conduct at the forum.

Facts:

Katherine Griffis, an Alabama teacher, specialized in Egyptian history and alleged that Marianne Luban, a Minnesota resident, posted a message on the internet challenging Griffis’ credentials, and accused Griffis of obtaining her degree from a box of cracker jacks. Griffis obtained a judgment in an Alabama district court against Luban for defamation and also an injunction to prevent such allegations. On appeal, the court of appeals vacated the referee's order because it had not been confirmed or countersigned by a district court judge. In the interim, Luban petitioned for bankruptcy, and on March 15, 2000, the bankruptcy court discharged the $ 25,000 judgment from the Alabama court. In March 2000, Luban renewed her motion in district court to vacate the Alabama judgment, and Griffis filed a cross-motion to enforce the Alabama injunction. The court found that the Alabama district court had personal jurisdiction over Luban and therefore the judgment must be given full faith and credit. Judgment was entered on December 21, 2000. On Luban's appeal, the court of appeals affirmed, ruling that the district court did not err in its determination that the Alabama court properly exercised personal jurisdiction over Luban. The court of appeals concluded that Luban was subject to the Alabama court's jurisdiction because she made potentially defamatory statements that were being read in Alabama and had knowledge of the effect of those statements in Alabama. Luban sought and was granted review in this court.

Issue:

Did the Ramsey County District Court correctly determine that the Alabama district court had personal jurisdiction over Luban so that the Alabama judgment is entitled to full faith and credit in the Minnesota courts?

Answer:

No.

Conclusion:

The court applied the three-prong Calder effects test as set forth by the United States Third Circuit Court to determine whether the Minnesota district court could enforce the Alabama judgment. The court held that the record did not demonstrate that Luban expressly aimed her allegedly tortious conduct at the Alabama forum so as to satisfy the third prong of the test. The mere fact that Luban knew that Griffis resided in Alabama was not sufficient to extend personal jurisdiction over Luban in Alabama, because that knowledge did not demonstrate targeting of Alabama as the focal point of the allegedly defamatory statements. Thus, the judgment of the Alabama court was not entitled to full faith and credit in Minnesota.