Rios v. Fergusan

Majority - Frazzini, J.

Yes, a state court has personal jurisdiction over a non-resident who specifically targets a resident with threats via the internet. To establish personal jurisdiction, the court first applied Connecticut's long-arm statute, finding that Fergusan's conduct qualified as committing a "tortious act within the state." The court reasoned that, like sending a threatening letter or email into the state, posting a video on YouTube specifically aimed at a Connecticut resident with the intent to cause fear constitutes a tortious act occurring where the harm is felt. The court distinguished this from a general internet posting, adopting a "targeting" standard from cases like Young v. New Haven Advocate, which requires a manifest intent to direct the activity at the forum state. It found that Fergusan's video was not a passive posting but was purposefully directed at Rios in Connecticut, satisfying the statute under the logic of the Calder v. Jones "effects test." Second, the court found that exercising jurisdiction comports with constitutional due process. Fergusan established sufficient "minimum contacts" with Connecticut by purposefully directing his threatening conduct at a resident there, making it foreseeable he could be haled into a Connecticut court. The court concluded that exercising jurisdiction was reasonable and did not offend traditional notions of fair play and substantial justice, given Connecticut's strong interest in protecting its citizens from domestic abuse and the plaintiff's interest in obtaining convenient relief.