Olukoya v. Badejo

Background

The plaintiffs brought a state-law defamation case against Maureen Badejo and other defendants. The opinion describes Badejo as a foreign national who appears to be a Nigerian citizen and resides in the United Kingdom. The plaintiffs alleged that Badejo posted defamatory material on an online news site called Gio TV and through Facebook, YouTube, and Snapchat.

The clerk entered the defendants’ default after they did not respond. The plaintiffs then moved for default judgment, which is a request for the court to enter judgment because a defendant failed to participate in the case. At an earlier case-management conference, the court questioned whether it had subject-matter or personal jurisdiction. Badejo later disputed the court’s jurisdiction.

Personal Jurisdiction

Personal jurisdiction is a court’s authority over a defendant. Because no federal statute supplied a different rule, the court applied California law and the constitutional requirement that a defendant have sufficient connections, or “minimum contacts,” with the state for the lawsuit to be fair.

The court found that the plaintiffs had not shown general personal jurisdiction. They did not argue that the defendants were domiciled in California or that their activities there were substantial, continuous, and systematic. The allegations that Badejo was a Nigerian-born blogger residing in the United Kingdom and that Gio TV was accessible through social-media platforms were insufficient.

The court also found no specific personal jurisdiction. In a tort case, the relevant test asks whether the defendant intentionally acted, expressly aimed the conduct at California, and caused harm the defendant knew was likely to be suffered there. The court found that the alleged online posts satisfied the intentional-act requirement, but not the express-aiming requirement.

The posts and video titles referred to matters involving the United Kingdom, Austria, Nigeria, and Maryland. They did not mention California or directly target the state. The plaintiffs argued that statements about Maryland litigation targeted an Oakland branch of their religious organization because that branch was allegedly connected to the importation of books discussed in the statements. The court found that argument required unsupported inferences. It also found that the quoted statements did not mention the Maryland litigation, California, or the Oakland branch.

Because the plaintiffs failed to establish the required California connection, the court held that it lacked personal jurisdiction over the defendants. The court did not decide whether the plaintiffs could satisfy the test’s third requirement—whether exercising jurisdiction would be reasonable.

Disposition

The court denied the plaintiffs’ motion for default judgment and dismissed the case for lack of personal jurisdiction. The clerk was directed to terminate the case. Judge Gilliam signed the order.