Walden v. Fiore
188 L. Ed. 2d 12 · Supreme Court of the United States · 2014
Facts
A Georgia police officer, deputized as a DEA agent, searched respondents at the Atlanta airport, seized a large amount of cash, and later allegedly drafted a false probable cause affidavit in Georgia to support forfeiture. Respondents, who resided in Nevada, sued the officer in Nevada federal court for Fourth Amendment violations after their funds were eventually returned. The District Court dismissed for lack of personal jurisdiction, but the Ninth Circuit reversed, finding jurisdiction based on the officer's knowledge that his actions would affect Nevada residents.
Issue
Can a federal court in Nevada exercise specific personal jurisdiction over a Georgia police officer whose alleged tortious conduct occurred entirely in Georgia, based solely on the officer's knowledge that his actions would affect plaintiffs with connections to Nevada?
Holding
No, the District Court in Nevada lacked personal jurisdiction over the petitioner. The Supreme Court reversed the Ninth Circuit, holding that the petitioner lacked the necessary minimum contacts with Nevada because his conduct occurred entirely in Georgia and the mere fact that his actions affected plaintiffs with forum connections is insufficient.
Rule
Specific personal jurisdiction requires that the defendant's suit-related conduct create a substantial connection with the forum State, arising from contacts that the defendant himself creates with the forum. The analysis focuses on the defendant's contacts with the forum State itself, not merely with persons residing there, and mere injury to a forum resident is not a sufficient connection to the forum.
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