Spca of Upstate New York, Inc., Appellants v. American Working Collie Association, Respondents

Summary

The New York Court of Appeals affirmed the Appellate Division's dismissal, holding that the plaintiffs failed to establish personal jurisdiction over the out-of-state defendants under CPLR 302(a)(1) because the defendants' contacts with New York were not purposeful enough and lacked a substantial relationship to the defamation claim. The majority emphasized New York's narrow approach to long‑arm jurisdiction in defamation cases to protect free speech. A dissent argued that the defendants' activities were purposeful and sufficiently related to the alleged statements, and therefore personal jurisdiction should have been found.