YOUNG v.

NEW HAVEN ADVOCATE

United States, Court of Appeals,
Fourth Circuit, 2002
315 F.3d 256 (4th Cir. 2002)
Facts: The appellants are two Connecticut newspapers New Haven Advocate and Hartford
Courant, their editors Gail Thompson and Brian Toolan, and their reporters Camille Jackson and
Amy Pagnozzi. The appellee is Stanley Young, a warden at Wallens Ridge in Virginia. The
newspaper and newspaper defendants are appealing the Virginia courts ruling of defamation of
Stanley Young.
Connecticuts maximum security prisons were overcrowded with inmates and to relieve
the situation Connecticut transferred about 500 prisoners, mostly of African American and
Hispanic descent, to the Wallens Ridge State Prison in Virginia in late 1999 where the appelle
worked as a warden. The state of Connecticut was in an uproar regarding this arrangement and
newspapers all over Connecticut including the appellants began reporting on this matter. On
March 30, 2000, the New Haven Advocate published an article written by appellant Camille
Jackson in regards to the transfer of the inmates. The article talked about the grim conditions of
the Virginia prison that mentioned in a class action that Connection inmates filed against
Wallens Ridge and the appellee concerning the lack of proper hygiene, medical care, and denial
of religious privileges. Lastly, the article mentioned concerns that a Connecticut state senator had
about Confederate Civil War memorabilia in the appellees office. Around the same time, the
Hartford Courants published an article written by appellant Amy Pagnozzi, which questioned
the relocation of Connecticut inmates to Virginia. The appellant also addressed handwritten
letters from the inmates that talked cruelty from the guards and in addition the appellant referred
to the prisons as a cut-rate gulag.
On May 12, 2000, the appellee sued the appellants for libel in a diversity action filed in
the Western District of Virginia. He claimed the newspapers articles made him come across as
a racist that encourages abuse of inmates by guards. The appelle claimed that the appellants
circulated these defamatory articles by posting them on their website. The newspaper filed
motion to dismiss the complaint under Federal Rule of Civil Procedure.
Procedural History: The initial ruling of Young v. New Haven Advocate at the lower level
court in the Western District of Virginia ruled in favor of Warden Young. The case being argued
was in regards to the defamation of Warden Young by the Connecticut newspapers. The ruling
was later appealed to the United States Court of Appeals, Fourth Circuit under the motion to
dismiss the complaint under the Federal Rule of Civil Procedure on the ground that the court
lacked personal jurisdiction over the newspaper. Justice Baldock presides over the case on June
3, 2002.

Issues: The main issues for consideration by the Court of Appeals: 1) are did the district court
lack personal jurisdiction over them under Virginias long arm statue, 2) did the defendant have
sufficient minimum contacts, 3) what audience were the newspaper intended for.
Holdings/Decision: No, the district court did not lack personal jurisdiction over the newspapers
under Virginias long arm statue, this is because the appellants internet activities led to the
defamation of the appellee. Yes, the defendant had sufficient minimum contacts. The audience
the newspapers were intended for was the publishing town of the paper and surrounding towns.
Rationale: On the issue of the long arm statue, Virginia had no jurisdiction over the Connecticut
newspapers. The appellants did not have any traditional contacts with the state of Virginia
including business or assets nor did they produce any sort of revenue from Virginia. The website
these articles were published on did not have any content that would connect to readers in
Virginia and most of the postings were used for advertising as a source of jobs in Connecticut.
See Young v. New Haven Advocate, 315 F.3d 256 (4th Cir. 2002). The court decided that the
internet activities were sufficient to meet the requirements of due process.
Disposition: The Court of Appeals reserved the order of the district court denying the motions to
dismiss for lack of personal jurisdiction made by the appellants. There was no remedy granted in
this case, just dismissal of lawsuit.
Concurring/Dissenting Opinions: There was a concurring opinion given by Justice Michael.
He discussed the deciding factor in the ruling of the appeal was whether the appellants subject
themselves to personal jurisdiction in Virginia by posting on the internet. Their decision was that
it was unconstitutional because the website or articles was not intended for a Virginia audience.
Analysis: I agree the judges decision in this case. In Youngs case, I dont the newspapers were
trying to defame his good name. New Haven Advocate and the Hartford Courant were just doing
their jobs as journalist and keeping their community informed. The opinion stated by Justice
Michael was an intelligent deciding factor in the ruling of the case. Granted the long arm statue
may have worked in this case if the newspaper had appealed to a bigger audience or even tickled
to the state of Virginia. I am surprised that the Virginia court felt that Stanley Young had enough
probable cause to sue the two Connecticut newspapers, because what they wrote about was not
defaming and was the truth.