Church of Scientology of California, a Nonprofit California Corporation v. James E. Adams, Elaine Viets, Pulitzer Publishing Co., Inc.

The Church of Scientology of California (California Church), a California corporation, appeals from a judgment dismissing its action for libel. The suit is against the Pulitzer Publishing Co., publisher of the St. Louis Post-Dispatch newspaper, and James E. Adams and Elaine Viets, principal authors of the newspaper articles in question. The district court dismissed the action against appellees for lack of personal jurisdiction and ruled, alternatively, that the complaint fails to state a claim upon which relief may be granted. We hold that the trial court was correct in concluding that it did not have jurisdiction over the appellees, and it is not necessary for us to address the district court’s alternative ruling.

The Post-Dispatch published a series of five articles about Scientology on March 3 through 7, 1974. The articles discussed Scientology generally and made particular reference to the Church of Scientology of Missouri. In preparing the articles, Adams and Viets interviewed local leaders of the Missouri Church of Scientology and former members of that Scientology branch as well as former staff members of the Toronto Scientology office. The articles were written in St.…