New York Court of Appeals

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

February 9, 201218 N.Y.3d 400

Summary

The Court of Appeals held 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 sufficiently related to the alleged defamatory statements. The Court affirmed the Appellate Division's dismissal, emphasizing the narrow approach to long‑arm jurisdiction in defamation cases. Justice Pigott dissented, arguing that the defendants' activities did constitute purposeful transacting of business and a substantial relationship to the claims.