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Revell v. Lidov | 317 F.3d 467 (2002)

Pan Am Flight 103 blew up over Lockerbie, Scotland, in 1988. Though Libyan leader Muammar Gaddafi eventually accepted responsibility, the story behind the bombing sparked endless speculation. One man’s published hypothesis of United States government involvement led to the case Revell versus Lidov, which considered the reach of websites for purposes of diversity jurisdiction.

Hart Lidov was a professor at Harvard Medical School who lived in Massachusetts. Lidov wrote an article in which he claimed that the Reagan administration had advance warning that terrorists planned to plant a bomb on Pan Am Flight 103 but deliberately failed to prevent it. He accused Buck Revell, Associate Deputy Director of the FBI, of covering up the conspiracy. Lidov posted this article on an open forum on a website maintained by the Columbia University School of Journalism, which is located in New York.

Revell, who lived in Texas, sued Lidov and Columbia in Texas federal court. The district court dismissed his claim for lack of personal jurisdiction. Revell appealed to the Fifth Circuit.

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