Federal Court Addresses Jurisdiction Over Claims of Defamation Over the Internet

In the case of Rhodes v. Azeff, No. 2:22-CV-00101-WSH (W.D. Pa. Jan. 29, 2025 Hardy, J.), the court addressed issues of personal jurisdiction that were based upon alleged defamatory statements that were published online.

In this case, the court granted a Defendant’s Motion to Dismiss this case for lack of personal jurisdiction and also granted the Motion to Dismiss the counterclaims.

In this decision, the court provided an excellent overview as to the standard of review relative to the issue of personal jurisdiction over a Defendant.

The court reiterated Third Circuit law that publishing statements on the internet does not subject the author to personal jurisdiction anywhere in the world from which a user could access the internet.

The court noted that an out-of-state person does not expressly target Pennsylvania nearly by publishing statements on the internet that are accessible from Pennsylvania.

Anyone wishing to review a copy of this decision may click this LINK.


I send thanks to Attorney Thomas McDonnell of the Pittsburgh office of the Summers, McDonnell, Hudak, Guthrie & Rauch, P.C. law firm for bringing this case to my attention.