Business Facebook page did not support personal jurisdiction out of state

Woodhurst v. Manny’s Inc., 2013 WL 1452929 (Iowa App. April 10, 2013)

Plaintiffs alleged that defendant – a bar in Illinois just a few miles from the Iowa border – was liable for serving alcohol to one of its patrons who crossed over to Iowa and shot one of the plaintiffs. The Iowa court in which the suit was pending dismissed for lack of personal jurisdiction. Plaintiff sought review of the dismissal. On appeal, the Iowa Court of Appeals affirmed.

The court found there was no evidence that defendant “purposefully directed” its advertisements via its Facebook and MySpace pages to Iowa residents. So the case establishes that having a social media presence – even an interactive one like a Facebook page – does not automatically mean that a company will be subject to suit everywhere the page is available. Courts apparently require something more for activity to be purposefully directed.