Sixth Circuit Affirms Dismissal for Lack of Personal Jurisdiction Over Out-of-State Twitter Messages
To establish jurisdiction over a defendant that is not domiciled in the forum, plaintiffs must generally demonstrate a substantial relationship between that forum and the defendant’s conduct giving rise to the suit. An interesting question arises, however, when the out-of-state conduct at issue occurs on the Internet and has effects in the forum state. In a recent decision by the United States Court of Appeals for the Sixth Circuit, Blessing v. Chandrasekhar, 988 F.3d 889 (6th Cir. 2021), the court considered whether posting allegedly tortious messages on Twitter, without more, could expose the posters to jurisdiction wherever the subjects of the tweets resided. In holding that it could not, the Sixth Circuit held that there must be additional contacts by the defendant connecting them to the forum for the exercise of jurisdiction to be proper. The decision reaffirms that personal jurisdiction cannot be based solely on the effects of conduct in a forum state.