Frank Sinatra v. National Enquirer, Inc., and Clinic La Prairie, S.A.

Appellee Frank Sinatra brought an action under Cal.Civ.Code § 3344 (1987 Supp.) against Clinic La Prairie, S.A. (“Clinic”) over statements made by the Clinic’s employees that were published in a national tabloid. Clinic employees, when interviewed in Switzerland by reporters for the magazine, The National Enquirer, falsely stated that Sinatra visited and was given youth regeneration treatments at the Clinic. The Clinic unsuccessfully entered a special appearance to challenge the district court’s assertion of in personam jurisdiction over it. The Clinic renews its jurisdictional challenge on appeal from a judgment for Sinatra.

The question on appeal involves whether statements made by employees of a Swiss clinic to a Florida corporation’s reporter about a California resident, which are the foundation for an article published in a nationally circulated magazine, are sufficient minimum contacts to establish personal jurisdiction in California. This appeal involves the interaction between the “effects” reasoning of Calder v. Jones, 465 U.S. 783 , 104 S.Ct. 1482 , 79 L.Ed.2d 804 (1984), and the reasonableness focus in Asahi Metal Industries v. Superior Court of Solano County, 480 U.S.…