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Fifth Circuit declines to assert personal jurisdiction in defamation case when the forum state was not specifically targeted. (Internet Law Update).
In an action for defamation, Oliver Revell sued Hart Lidov and Columbia University over Lidov's authorship of an article posted on an electronic bulletin board hosted by Columbia University. [Revell v. Lidov, 2002 WL 31890992 (5th Cir. 2002).] Upon a Federal Rules of civil Procedure Rule 12(b)(2) motion by the defense, the action was dismissed for lack of personal jurisdiction over either defendant. Revell then appealed to the Fifth Circuit.
Lidov, an assistant professor at Harvard, wrote an article regarding the 1988 terrorist bombing of Pan Am Flight 103 over Lockerbie, Scotland. The article alleged that there existed a broad politically motivated conspiracy among members of the Reagan administration. …
