Walden v. Fiore

Citation. 134 S. Ct. 1115 (2014)

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Citation134 S. Ct. 1115 (2014)

Brief Fact Summary.

Plaintiffs filed a tort suit against Defendant in Federal District Court in Nevada. The district court dismissed the suit, finding that the Georgia search and seizure did not establish a basis to exercise personal jurisdiction in Nevada. The Ninth Circuit reversed, holding that the District Court could properly exercise jurisdiction because Defendant had submitted the false probable cause affidavit with the knowledge that it would affect persons with significant Nevada connections. The United States Supreme Court granted certiorari to review.

Synopsis of Rule of Law.

Due process does not permit the exercise of personal jurisdiction over a nonresident civil defendant if the defendant’s sole contact with the forum state is knowledge that the defendant’s tortious conduct committed outside the forum state has an effect on the plaintiff in that state.

Points of Law - Legal Principles in this Case for Law Students.

Mere injury to a forum resident is not a sufficient connection to the forum, and an injury is jurisdictionally relevant only insofar as it shows that the defendant has formed a contact with the forum State.

View Full Point of Law

Plaintiffs were detained at an airport in Puerto Rico by TSA agents. The TSA agents discovered nearly $97,000 in cash in one of Plaintiff Fiore’s carry-on bags. Plaintiffs explained that they were professional gamblers and had won the money at a San Juan casino. Plaintiffs were subsequently cleared for departure to Atlanta, Georgia, but law-enforcement officials in San Juan alerted a Drug Enforcement Administration (DEA) task force at the Atlanta airport to Plaintiffs’ impending arrival. Upon the plaintiffs’ arrival in Atlanta, Defendant and the task force approached Plaintiffs, questioned them about the source of the money, and used a drug-sniffing dog on Plaintiff Fiore’s bag. Although the dog did not find any narcotics on Plaintiff Fiore’s bag, Defendant seized the cash despite Plaintiff Fiore’s gambling explanation. Eventually, the money was returned to Plaintiffs. Plaintiffs filed suit against Defendant in federal district court in Nevada, seeking damages pursuant to Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S. 388 (1971). Plaintiffs alleged that after they returned to their Nevada residence, Defendant helped draft a false probable cause affidavit in support of the funds’ forfeiture and forwarded it to a United States Attorney’s Office in Georgia. In the end, no forfeiture complaint was filed, and Plaintiffs’ funds were returned. The district court granted Defendant’s motion to dismiss the complaint on the ground that the court did not have personal jurisdiction over Defendant. Plaintiffs appealed. A divided panel of the court of appeals reversed. The United States Supreme Court granted certiorari to review.

Issue.

Does due process permit the exercise of personal jurisdiction over a nonresident civil defendant if the defendant’s sole contact with the forum state is knowledge that the defendant’s tortious conduct committed outside the forum state has an effect on the plaintiff in that state?

Held.

No. The court held that Nevada did not have jurisdiction over Defendant when the conduct of Defendant, a Georgia police officer, occurred entirely in Georgia, even if his conduct affected Plaintiffs with connections to Nevada.

Discussion.

Due process does not permit the exercise of personal jurisdiction over a nonresident civil defendant if the defendant’s sole contact with the forum state is knowledge that the defendant’s tortious conduct committed outside the forum state has an effect on the plaintiff in that state. A court may exercise personal jurisdiction over a defendant consistent with due process if the defendant has substantial personal contacts or connection with the forum state. The relationship to the forum state must arise from contacts that the defendant himself creates with the forum state. There may be sufficient contact for personal jurisdiction if a defendant is personally located in the forum state or travels to, conducts activities within, contacts anyone residing in, or sends anything to the forum state . However, personal jurisdiction may not be exercised over a nonresident civil defendant if the defendant’s sole contact with the forum state is knowledge that the defendant’s tortious conduct committed outside the forum state has an effect on the plaintiff in that state.

Here, Defendant has had no personal contacts with Nevada other than his one-time interaction with Plaintiffs at the Atlanta airport. Because Defendant’s only affiliation with Nevada stemmed from his interaction with Plaintiffs, Defendant lacked the minimum contacts with Nevada necessary for the district court to exercise personal jurisdiction over him. Therefore, the judgment of the court of appeals was reversed, and the matter was remanded for further proceedings.