Griffis v. Luban [1]

In September 1997, Katherine Griffis sued Marianne Luban for defamation in Alabama state court after Luban criticized Griffis's academic credentials on the sci.archaeology [2] USEnet newsgroup.  Griffis also sought an injunction against Luban to prevent her from republishing any of her accusations.

According to court documents, Luban's lawyer told her not to answer Griffis's complaint, saying that Alabama had no personal jurisdiction over her.  Luban did not answer, and in January 1998, the Alabama court entered a default judgment against her, awarding Griffis $25,000 and granting her request for an injunction. 

When Griffis attempted to enforce the judgment and injunction in Minnesota, Luban moved in Minnesota state court to vacate the Alabama court's judgment on jurisdictional grounds.  The Minnesota trial court found, however, that the Alabama court had personal jurisdiction over Luban.  Luban appealed, but the Minnesota Court of Appeals affirmed.  Both the trial and appeals courts ruled that Luban was subject to Alabama's jurisdiction because Luban knew that Griffis was an Alabama resident and that her accusations would have an effect in Alabama.

Luban appealed again, this time to the Minnesota Supreme Court, which ruled in her favor [3].  The court held that Luban's knowledge of Griffis's Alabama residence was insufficient for Luban to reasonably expect to be sued in Alabama.  According to the court, for Alabama to have jurisdiction over Luban, Griffis would have to show that Luban specifically targeted Alabama in making her accusations.  Griffis failed to prove this, the court reasoned, because she only showed that Luban targeted the sci.archaeology community, which did not have a sufficient relationship with the State of Alabama to make Luban subject to Alabama's jurisdiction.