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Issues: The main issues for consideration by the Court of Appeals: 1) are did the district court
lack personal jurisdiction over them under Virginias long arm statue, 2) did the defendant have
sufficient minimum contacts, 3) what audience were the newspaper intended for.
Holdings/Decision: No, the district court did not lack personal jurisdiction over the newspapers
under Virginias long arm statue, this is because the appellants internet activities led to the
defamation of the appellee. Yes, the defendant had sufficient minimum contacts. The audience
the newspapers were intended for was the publishing town of the paper and surrounding towns.
Rationale: On the issue of the long arm statue, Virginia had no jurisdiction over the Connecticut
newspapers. The appellants did not have any traditional contacts with the state of Virginia
including business or assets nor did they produce any sort of revenue from Virginia. The website
these articles were published on did not have any content that would connect to readers in
Virginia and most of the postings were used for advertising as a source of jobs in Connecticut.
See Young v. New Haven Advocate, 315 F.3d 256 (4th Cir. 2002). The court decided that the
internet activities were sufficient to meet the requirements of due process.
Disposition: The Court of Appeals reserved the order of the district court denying the motions to
dismiss for lack of personal jurisdiction made by the appellants. There was no remedy granted in
this case, just dismissal of lawsuit.
Concurring/Dissenting Opinions: There was a concurring opinion given by Justice Michael.
He discussed the deciding factor in the ruling of the appeal was whether the appellants subject
themselves to personal jurisdiction in Virginia by posting on the internet. Their decision was that
it was unconstitutional because the website or articles was not intended for a Virginia audience.
Analysis: I agree the judges decision in this case. In Youngs case, I dont the newspapers were
trying to defame his good name. New Haven Advocate and the Hartford Courant were just doing
their jobs as journalist and keeping their community informed. The opinion stated by Justice
Michael was an intelligent deciding factor in the ruling of the case. Granted the long arm statue
may have worked in this case if the newspaper had appealed to a bigger audience or even tickled
to the state of Virginia. I am surprised that the Virginia court felt that Stanley Young had enough
probable cause to sue the two Connecticut newspapers, because what they wrote about was not
defaming and was the truth.