So the Montana Supreme Court holds, in Groo v. Montana Eleventh Jud. Dist. Ct., written by Chief Justice McGrath, joined by Justices Beth Baker, James Jeremiah Shea, and Jim Rice. A few passages:
The underlying case arises from Groo's purposeful and substantial use of social media to affect the business operations of Triple D Game Farm, Inc. (Triple D). In response, Triple D filed a Complaint and Demand for Jury Trial alleging Tortious Interference with Contractual Relations and Tortious Interference with Prospective Economic Advantage claims against Groo.
Groo moved to dismiss the claims against her for lack of personal jurisdiction. She contends that the statements she allegedly made on social media about Triple D did not create the minimum contacts with Montana as a forum nor constitute purposeful availment of the protections afforded by Montana law—both of which are required for a Montana court to exercise personal jurisdiction over an out-of-state defendant….
[S]imply posting information on the internet for anyone to see is not enough by itself to establish personal jurisdiction over a defendant. However, when a defendant engages in a targeted campaign against a Montana business, tags Montana residents and those doing business in Montana, and encourages them to refrain from doing or continuing actions in Montana, that person has purposefully directed conduct into Montana such that the Due Process Clause allows them to be haled into Montana courts.
