A New York woman will face a suit in Montana after the latter state's Supreme Court held that her critical social media posts about a Montana wildlife photography farm were sufficient for the state to invoke personal jurisdiction.

In a case of first impression, a deeply split Montana Supreme Court held 4-3 that the negative posts wildlife photographer Melissa Groo wrote about Triple D Game Farm created minimum contacts with the state and constituted personal availment for it to invoke jurisdiction despite Groo being a New York State resident and making the posts outside of Montana.