Milestones: Evangelize China Fellowship, Inc. v. Evangelize China Fellowship Hong Kong, 146 Cal. App. 3d 440 (1983)

Summary:

The parties are two missionary groups that split into two after an internecine dispute. Plaintiff then sued the defendant for libel, based on the theory that the offending publication was available in California. The court found that there was no personal jurisdiction over the defendant, because having some copies available in California was not sufficient minimum contact.

Takeaway:

Personal jurisdiction is the first line of defense for non-U.S. parties, but unfortunately, the line that establishes personal jurisdiction is very hazy. It is also potentially hazardous to rely on a case from 1983, when there has been huge developments in the personal jurisdiction doctrine in the last 30+ years. But someday, some time, you will need a case about personal jurisdiction involving defamatory material.