A New York appellate court recently dismissed a defamation lawsuit filed by John Doe against Jane Roe, both college students. The court ruled that it did not have jurisdiction over Roe, who was accused of making defamatory statements during a virtual disciplinary investigation at Princeton University. This decision could have significant implications for similar cases involving students attending out-of-state universities.

The case, Doe v. Roe (Docket No. CV-25-1023), was decided on November 5, 2026, by the Appellate Division of the Supreme Court of the State of New York. The ruling came after the Supreme Court of Tompkins County granted Roe's motion to dismiss the complaint, which Doe appealed.

Background

John Doe, the appellant, was an undergraduate student at Princeton University in New Jersey when he filed the lawsuit against Jane Roe, a student at Cornell University in New York. The dispute arose from statements that Roe allegedly made during a virtual disciplinary investigation regarding incidents that occurred at Princeton's campus.

Roe, who was interning in Washington, D.C., at the time, moved to dismiss the complaint, arguing that the court lacked personal jurisdiction over her. The Supreme Court agreed, leading to Doe's appeal. The key issue in the case was whether Roe maintained her legal residence in Washington State, which would affect the court's ability to hear the case.

The Ruling

The appellate court upheld the lower court's decision, concluding that it did not have general jurisdiction over Roe. The court stated, "Supreme Court correctly concluded that it did not have general jurisdiction over defendant." It emphasized that jurisdiction is typically based on a person's domicile, which requires both physical presence and the intent to make a place a permanent home.

In this case, the court found that Roe's parents were domiciled in Washington, and she had not demonstrated any intent to make New York her permanent home. The ruling noted that Roe returned to Washington during academic breaks and maintained the majority of her personal belongings there. The court also pointed out that Doe failed to provide evidence showing that Roe intended to establish New York as her permanent residence.

Impact

This ruling clarifies the requirements for establishing jurisdiction in defamation cases involving college students. It highlights that merely attending school in New York does not automatically subject a student to the state's jurisdiction for legal matters. The court stated that Roe's activities as a student did not constitute the type of continuous commercial presence necessary for general jurisdiction.

The decision may affect other students in similar situations, particularly those who attend out-of-state universities and may face legal actions in New York. It reinforces the importance of domicile in jurisdictional matters, which could lead to more strategic considerations for students involved in legal disputes.

What's Next

Doe may consider appealing the decision, but the court's ruling on jurisdiction is a significant barrier. Additionally, Doe has already filed a related defamation lawsuit against Roe in Washington State, asserting that she is domiciled there. The outcome of that case could further impact the ongoing legal battle between the two students.