170B Federal Courts

170BII Venue

170BII(A) In General

170Bk77 Corporations, Actions by or Against

170Bk81 k. Sales, Solicitation and Advertising.

Brunt of harm caused by brewing company owners who marketed a brand of malt liquor, using the name “Crazy Horse,” was suffered, and owners knew it was likely to be suffered, in South Dakota, as element of effects test for personal jurisdiction, where descendants of Crazy Horse resided in South Dakota, such use of his name was a shameful slur in Lakota culture, South Dakota Senators had objected to owners’ use of the name, and descendants had objected to the use of Crazy Horse’s name.
Estate of Witko v. Hornell Brewing Co., 156 F. Supp. 2d 1092 (D.S.D. 2001)