Doe v. Geller and Personal Jurisdiction Over Internet Activities

Personal jurisdiction is fundamental in American jurisprudence since it gives a court the power to bind parties with its ruling. Despite this subject’s mundane veneer, the concept is so complicated that it has inspired thousands of academic articles. A brief search on Westlaw under Law Reviews & Journals for the term “personal jurisdiction” yields nearly 10,000 results, while Lexis+ yields 14,662 for the same term. Even so, as the nature of human interaction has changed from in person, to in writing, to over the phone, and, most recently, to over the internet, the doctrine of personal jurisdiction has accommodated. Recent cases involving internet disputes have proven especially complicated, and, as such, federal courts have done their best to adapt personal jurisdiction to make it fair and effective in these novel circumstances. The following Note begins by reviewing the history of personal jurisdiction. Next, this Note covers the federal courts’ ongoing attempt to address the complexities of personal jurisdiction in the context of the internet in Zippo Manufacturing Co. v. Zippo Dot Com, Inc. (“Zippo”). Then, the Note discusses Zippo’s weaknesses and compares them with the analysis of Doe v. Geller. Finally, this Note proposes that courts return to the classical personal jurisdictional analysis for cases involving internet actions.