In the 1983 U.S. Supreme Court case Calder et al. v. Jones, actress Shirley Jones filed a libel suit in California against the National Enquirer and its Florida-based editor and writer (Calder). The defendants argued that they were not subject to jurisdiction in California as their activities were based out of Florida; however, the court ruled otherwise. It held that if an individual's actions are aimed at causing harm within another state, then they can be subjected to jurisdiction there even if their physical presence is lacking. This ruling was significant because it established "purposeful direction" as a standard for personal jurisdiction in intentional tort cases - meaning individuals or entities could face legal consequences outside of their home states for harmful actions directed elsewhere.

In the dissenting opinion for Calder et al. v. Jones, Justice Byron White argued that the majority's decision to allow California courts jurisdiction over a Florida-based tabloid and its editors was incorrect. He contended that simply because an article is circulated in a state does not mean it can be subject to personal jurisdiction there, especially when those responsible for its content have no other connections with said state. The defendants did not engage in any activity within California beyond sending their publication into circulation; they had no offices or employees there nor did they solicit business or profits from Californians specifically more than any other readership group nationwide. Therefore, according to Justice White’s view, this case should fall under Florida's jurisdiction where the National Enquirer and its editing activities were based rather than being subjected to litigation in every location where their newspapers happened to circulate.