Apply the jurisdiction test to the following scenario: Two Connecticut newspapers were investigating conditions of confinement at a Virginia prison. The story was relevant in Connecticut because some of the overflow prison population in Connecticut was being transferred to a Virginia facility. Articles that included content critical of the Virginia prison and its management appeared in the newspaper in both its print and online editions. The Virginia prison warden sued in federal court in Virginia, claiming that the online content was seen in Virginia and had defamed him there. How would the court decide if Virginia has jurisdiction?

What will be an ideal response?

The court would carefully review the articles and determine the target audience. If the court said the target audience was local (Connecticut), then Virginia would not have jurisdiction to hear the claim. Placing content online is not sufficient by itself to subject a person to the jurisdiction in another state just because the information could be accessed there.