SCOTUS Rules In Personal Jurisdiction Case.

SCOTUS Rules In Personal Jurisdiction Case.

In the case of Walden v Fiore, a Georgia police officer working with the DEA, at a Georgia airport searched Fiore (Plaintiff).  As a result of the search Walden seized a large sum of cash from Fiore.  Fiore was a Nevada resident claimed that after they returned to their home in Nevada, Walden helped draft a false probable cause affidavit in support of the forfeiture.  The US Attorney in Georgia.  Ultimately the fund were returned as the government did not file a forfeiture action.  Fiore filed lawsuit in the United States District Court for the District of Nevada.  The complaint sought money damages for what Fiore claimed illegal search and seizure.

The district Court dismissed the suit.  The Court ruled since the search and seizure occurred in Georgia, Nevada did not have personal jurisdiction over the defendant.  Fiore appealed to the Ninth Circuit reversed the District Court holding that Nevada had personal jurisdiction because Walden submitted the alleged false probable cause affidavit with the knowledge that it would affect persons in Nevada.  Walden appealed to SCOTUS.

SCOTUS reversed.  Writing for the majority, Justice Thomas in short wrote that: (1) the 14th amendment constrains a State’s authority to bind a non-resident (relying on the classic World-Wide Volkswagen v Woodson) and that it requires that the nonresident, in this case Walden, have certain minimal contacts with the forum state (relying on good ol I-Shoe) and (2) that here Walden lacked the minimal contacts, stating that no part of Walden’s conduct occurred in Nevada, he had no “jurisdictionally relevant contacts” to support personal jursidiction.

Thomas wrote: “The proper question is whether the defendant’s conduct connects him to the forum in a meaningful way: Here, respondents’ claimed injury does not evince such a connection.”