Schwarzenegger

Arnold Schwarzenegger, an internationally-known movie star and, currently, the Governor of California, appeals the district court’s dismissal of his suit against Fred Martin Motor Company (“Fred Martin”), an Ohio car dealership, for lack of personal jurisdiction. Fred Martin had run a series of five fullpage color advertisements in the Akron Beacon Journal, a locally-circulated Ohio newspaper. Each advertisement included a small photograph of Schwarzenegger, portrayed as the “Terminator,” without his permission. Schwarzenegger brought suit in California, alleging, inter alia, that these unauthorized uses of his image infringed his right of publicity. We affirm the district court’s dismissal for lack of personal jurisdiction.

I. Background

Schwarzenegger is a resident of California. When Schwarzenegger brought this suit, he was a private citizen and movie star, best known for his roles as a musclebound hero of action films and distinctive Austrian accent. As explained in his complaint, Schwarzenegger was generally cast as the lead character in so-called “star-driven” films. One of Schwarzenegger’s most popular and readily-recognizable film roles is that of the title character in…