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When you have two regular people suing each other, and they are in different states, the jurisdiction usually settles where the recording happened.
This was a criminal rather than civil case & the question was whether the state of California could enforce its two-party consent law with regard to a call originating from + recorded in Georgia. The ruling determined that yes, California can prosecute under those circumstances.
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Whether a civil suit could be approached in a similar way, I don't know
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The point I am making is not an easily googlable one, but i think is the crux. There are all sort of issues with bringing charges against an individual in a different state, with a crime that happened in a different state. The only practical reason California can do so is because
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