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Cacdac v. Sweet
Citations: 761 F. Supp. 594; 1989 U.S. Dist. LEXIS 17469; 1989 WL 247535Docket: TH 88-205-C
Court: District Court, S.D. Indiana; September 6, 1989; Federal District Court
The Court addresses the defendant William H. Sweet, M.D.'s Motion to Dismiss, arguing lack of personal jurisdiction in a defamation lawsuit filed by Dr. Manuel Cacdac, M.D. The case stems from statements made by Dr. Sweet during a CBS News interview that Dr. Cacdac claims were defamatory and made with malice. Dr. Cacdac asserts that the Court has subject matter jurisdiction based on diversity, as he is an Indiana resident and Dr. Sweet is from Massachusetts. Dr. Sweet contends that he has minimal contacts with Indiana, having only visited the state three times for testimony in unrelated medical malpractice cases involving Dr. Cacdac. He argues that the statements in question were made in Boston, and therefore, Indiana lacks personal jurisdiction over him. Dr. Cacdac counters that Indiana's "long arm" statute allows for jurisdiction due to the national broadcast of the interview, which he claims Dr. Sweet knew would reach Indiana. The relevant statute, Rule 4.4 of the Indiana Rules of Trial Procedure, outlines conditions under which a nonresident can be subject to Indiana's jurisdiction. Dr. Sweet’s affidavit asserts he was not compensated for his involvement in the Indiana cases, indicating a lack of business engagement within the state. The Court must determine if the jurisdiction under the Indiana long arm statute is applicable based on these facts. Dr. Cacdac has not alleged that Dr. Sweet made defamatory statements during his visits to Indiana; the statements in question were made in Boston. The Court determined that Dr. Sweet's three visits do not amount to "doing business" or causing personal injury within Indiana, making Rules 4.4(A)(1), (2), and (4) inapplicable. Jurisdiction, if applicable, would rely on Rule 4.4(A)(3), which initially suggests potential jurisdiction. However, the Court must also consider whether exercising jurisdiction complies with the Fourteenth Amendment's due process requirements, which necessitates that a defendant has "certain minimum contacts" with the forum state to avoid violating "traditional notions of fair play and substantial justice." The relationship between Dr. Sweet, Indiana, and the litigation subject matter—statements made in Massachusetts and aired nationally—was examined. Although "60 Minutes" has a significant audience in Indiana, the mere foreseeability of causing injury there does not suffice for jurisdiction. The Supreme Court's ruling in World-Wide Volkswagen emphasizes that a defendant must have sufficient connections to the forum state to reasonably anticipate being sued there. Based on the facts, the Court concluded that Dr. Sweet could not have reasonably foreseen being subject to jurisdiction in Indiana for statements made in Massachusetts. Consequently, the Court found that due process prevents the exercise of jurisdiction in this case. The defendants requested dismissal due to lack of personal jurisdiction, while the plaintiffs sought a transfer to the District Court in Boston. Given Indiana's two-year statute of limitations for intentional torts has expired, and to avoid penalizing the plaintiff due to venue uncertainties, the Court decided it would be in the interest of justice to transfer the case rather than dismiss it. Therefore, the Motion to Dismiss was denied, and the case was ordered to be transferred to the United States District Court for Boston, Massachusetts.