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Court of Appeals of New York


SPCA of Upstate New York, Inc. v. American Working Collie Ass'n, 6

In a defamation action brought by a New York SPCA against a Vermont resident, the appellate division's dismissal of the complaint for lack of personal jurisdiction is affirmed, where: 1) a defendant's three phone calls and two short visits, totaling less than three hours, in addition to the donation of cash and leashes, did not constitute purposeful activities related to the asserted cause of action that would justify bringing her before the New York courts; 2) the alleged defamatory statements were not written in or directed to New York; and 3) there was no substantial relationship between the allegedly defamatory statements and the defendants' New York activities.

Appellate Information

  • Decided 02/09/2012
  • Published 02/09/2012

Judges

  • Lippman

Court

  • Court of Appeals of New York

Counsel

  • For Appellant:
  • Martin J. McGuinness, Jonathan M. Bernstein

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