Walden v. Fiore

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Walden, a Georgia police officer working as a DEA agent at a Georgia airport, searched plaintiffs and seized a large amount of cash. Plaintiffs claim that after they returned to their Nevada residence, Walden helped draft a false probable cause affidavit in support of forfeiture and forwarded it to a Georgia office of the U.S. Attorney. No forfeiture complaint was filed and the funds were returned. Plaintiffs filed a tort suit in a Nevada District Court. The district court dismissed, finding that the Georgia search and seizure did not establish a basis for personal jurisdiction in Nevada. The Ninth Circuit reversed, reasoning that Walden submitted the affidavit with the knowledge that it would affect persons with significant Nevada connections. The Supreme Court reversed, holding that the district court lacked personal jurisdiction over Walden. The Due Process Clause limits state authority to bind a nonresident defendant to a judgment of its courts, requiring that the nonresident have “certain minimum contacts” with the forum state. For a state to exercise jurisdiction consistent with due process, a relationship must arise out of contacts that the defendant himself created with the forum itself, not with persons residing there. The plaintiff cannot be the only link between the defendant and the forum. Walden lacks those “minimal contacts” with Nevada. None of his conduct occurred in Nevada, and he formed no jurisdictionally relevant contacts with that forum. Mere injury to a forum resident is not a sufficient connection to the forum. The injury occurred in Nevada simply because that is where plaintiffs chose to be when they desired to use the seized funds. The Court also rejected an argument based on the origin of the funds. View "Walden v. Fiore" on Justia Law