Internet Solutions v. Marshall: Internet Defamation Case Dismissed for Lack of Personal Jurisdiction

A quick update on the Internet Solutions v. Marshall case, which I've blogged about at length previously. This case is significant to us because Tabatha Marshall, the defendant, was the first user of our website to submit information about her case through our threat entry form.

Yesterday, a federal district court in Florida dismissed the lawsuit against Marshall, who is a Washington resident, holding that it lacked personal jurisdiction over her. The court held that exercising personal jurisdiction over Marshall would violate the Due Process Clause because she lacked minimum contacts with Florida. Specifically, the court determined that Marshall's website,, did not justify hailing her into a Florida court because it was equally accessible to persons in all states and because Marshall's posts did "not specifically mention Florida or its residents." The court therefore distinguished the pre-Internet Supreme Court case, Calder v. Jones, 465 U.S. 783 (1984), which held that a California court could exercise jurisdiction over two Florida reporters who had "specifically target[ed] a California audience, ma[de] large distributions in California, and publish[ed] articles about a California resident."

Marc Randazza has additional commentary.


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