In the case of Calder v. Jones (465 U.S. 783 (1984)), a Florida newspaper slandered a California
resident. The newspaper did not contest jurisdiction (the newspaper is sold
there so the corporation had minimum contact with the State under the standard
of International Shoe v. Washington
(326 U.S. 310 (1945))), but they argued that the publisher and editor of the
magazine could not personally be sued in California because they personally had
no connections to California. The US Supreme Court found that the California
courts did have personal jurisdiction over the editor and publisher.
The US Supreme Court found
that the situation was similar to sending a letter bomb, or firing a gun
across State boundaries.
In either case, the
defendant is doing it with the specific intent to cause a crime in
another State. Therefore, they can be subject to personal jurisdiction.
Compare this case to the similar case of
Keeton v. Hustler Magazine (465
U.S. 770 (1984)).