Melissa Groo v. Amy Eddy, Judge, Montana Eleventh Judicial District Court

The Due Process Clause requires that in order to exercise specific personal jurisdiction, the defendant must have “purposefully directed its conduct into the forum state.” Bristol-Myers Squibb Co. v. Superior Court, 582 U.S. 255, 272 (2017). For cases alleging intentional torts, “the proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant’s conduct connects him to the forum in a meaningful way.” Walden v. Fiore, 571 U.S. 277, 290 (2014). In Walden, the Court left the applicable purposeful direction standard for intentional torts based on internet contacts “for another day.” Id. at 290, n.9. The question presented is: Whether the Due Process Clause permits a state court to exercise specific personal jurisdiction over a non-resident defendant in an intentional tort case based solely on a negative social media post about a business in the forum state, which tags forum state residents and non-residents who may do business with the forum state business.