Supreme Court Decides Walden v. Fiore

On February 25, 2014, the United States Supreme Court decided Walden v. Fiore, No. 12-574, holding unanimously that a federal court may exercise personal jurisdiction over a non-resident defendant only if the defendant has sufficient contacts with the state—rather than with residents of the state—to satisfy due process. A defendant's knowledge that the plaintiff was connected with the forum state is not enough.

In August 2006, Anthony Walden was a police officer working as a Drug Enforcement Administration agent at the Atlanta Hartsfield-Jackson Airport. As part of his duties, he seized $97,000 in cash from Gina Fiore and Keith Gipson, professional gamblers who claimed they won the money gambling in Puerto Rico. After returning home to Las Vegas, Fiore and Gipson requested return of the funds. Walden opposed their request and drafted an affidavit in Georgia to show probable cause for the funds' forfeiture. Ultimately, no forfeiture complaint was filed, and the funds were returned to Fiore and Gipson in Nevada.

Fiore and Gipson then filed suit against Walden in U.S. District Court for the District of Nevada, alleging that Walden violated their Fourth Amendment rights by (1) by seizing their cash without probable cause and (2) by drafting and forwarding a probable cause affidavit while knowing it contained false statements. The district court granted a motion to dismiss for lack of personal jurisdiction, but the Court of Appeals for the Ninth Circuit reversed, holding that exercise of personal jurisdiction over Walden in Nevada was proper because he "expressly aimed" his submission of the allegedly false affidavit at Nevada by submitting it with the knowledge that it would affect persons with a "significant connection" to Nevada.

The Supreme Court unanimously reversed. Applying "well-established principles of personal jurisdiction," it held that a federal court may not exercise personal jurisdiction over a non-resident defendant solely on the basis that the defendant knew his allegedly tortious conduct in one state would delay the return of funds to plaintiffs with connections in the forum state. The Court reiterated two core personal jurisdictional principles: (1) the connection to the forum state "must arise out of contacts that the defendant himself creates with the forum state," rather than the relationship between the plaintiff or third-parties and the forum; and (2) the focus must be on the defendant's contacts "with the forum state itself," rather than with persons who reside there. "Due process requires that a defendant be haled into court in a forum State based on his own affiliation with the State, not based on the random, fortuitous, or attenuated contacts he makes by interacting with other persons affiliated with the State." Because Walden never traveled to, conducted activities in, or sent anything or anyone to Nevada, the district court lacked personal jurisdiction over him. To rule otherwise—as the Ninth Circuit did—"impermissibly allows a plaintiff's contacts with the defendant and forum to drive the jurisdictional analysis."

Justice Thomas delivered the opinion for a unanimous court.

Download Opinion of the Court