Questions
1. The articles in a Minnesota newspaper were not targeted specifically toward a
North Dakota audience (and in fact is specifically aimed outside the state)
distinguishing the case from Calder v. Jones, 465 U.S. 783 (1984) (personal
jurisdiction found over out-of-state magazine where publication was aimed at the
forum), and the Defendant does not meet does the North Dakota Supreme Court's
jurisdictional analysis, in which exercise of jurisdiction is determined by the
level of interactivity and the commercial nature of the exchange of information
that occurs on the Internet. Does the North Dakota Supreme Court's
jurisdictional analysis violate traditional due process principles of personal
jurisdiction?
2. Although the Calder v. Jones “effects test,” initially seems to apply in this
case, when you look further, there are problems. In Wagner v. Miskin, Miskin, a
Minnesota editor, simply “linked to” and “posted” already public information on
a Web newspaper. Miskin was made responsible for making Wagner embarrassed by
linking to the local and national newspaper articles he himself had interviewed
in. After airing his views in public and after casting himself into the
limelight, Wagner made himself a limited purpose public figure. How much effect
if any did this actually have on Wagner to make public that which he himself has
already made public and does this case then meet the criteria of Calder v. Jones
or was the North Dakota Supreme Court's jurisdictional analysis incorrect ?
3. The Federal Telecommunications Act of 1996 grants the publisher of all
alleged defamations absolute privilege and preempts all State law on the matter
to the contrary. Should the “effects test,” established by this court for
evaluating personal jurisdiction over nonresident authors of allegedly
defamatory works, be read to require higher due process requirements for
personal jurisdiction over editors who simply “post” or “link to “ public
information or works of third parties other newspapers from other places that
already appear on the Internet ?
4. The North Dakota Constitution does not provide absolute privilege in the case
of quasi-judicial hearings. Here the North Dakota Court claimed “not heretofore
recognized a judicially-crafted ‘quasi-judicial privilege’” although the
Plaintiff clearly complains of damages that are within the scope of Defendant’s
defense of a public quasi-judicial hearing. Following this constitutional
deficiency, do the laws of a state that allows public quasi-judicial hearings to
be retried for libel or defamation have a chilling effect on pro se defendants
who need to speak in their own defense or speak to others while trying to
discover facts to prove their innocence?
5. Does a state that allows trials of whistle-blowers for libel in the case of
reports to authorities of public concern, and where witnesses of potential
criminal activity who come forth are subjected to retaliation in the form of
defamation and libel lawsuit(s), result in the effect of the chilling of free
speech of witnesses?
6. Does the manipulation by the North Dakota Attorney General’s office of
sending uniformed police officers to intimidate potential witnesses and the
North Dakota Attorney General’s office ordering witnesses not to speak have a
chilling effect on free speech in North Dakota?