United States v. Tarek Obaid, 971 F.3d 1095

Tarek Obaid, a Saudi citizen and CEO of PetroSaudi International (PSI), allegedly participated in transfers from the Malaysian 1MDB fund; he personally received about $153 million traced through a New York-processed Swiss account (the Good Star Account).
Obaid wired $2 million from his Swiss account to a California bank to purchase 2,500,000 Series D preferred shares of Palantir.
The United States filed an in rem civil forfeiture action against the Palantir shares, alleging they were traceable to proceeds of the 1MDB fraud and money-laundering scheme.
Obaid admitted ownership of the shares and moved to dismiss for lack of personal jurisdiction over him and improper venue (the shares were not alleged to be located in the Central District of California).
The district court denied dismissal: it held that (1) Shaffer v. Heitner’s minimum-contacts test did not apply to a true in rem forfeiture proceeding and (2) venue was proper under 28 U.S.C. § 1355(b) because sufficient acts giving rise to the forfeiture occurred in the Central District.
The Ninth Circuit affirmed: it treated Shaffer as limited to quasi in rem proceedings, relied on Hood to permit in rem jurisdiction based on the res, and upheld venue under § 1355(b).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an in rem civil forfeiture requires personal jurisdiction/minimum contacts over the property owner (Shaffer applicability)	Government: forfeiture is in rem; jurisdiction focuses on the res, not owner contacts; Shaffer does not bar in rem forfeiture jurisdiction.	Obaid: Shaffer requires International Shoe minimum-contacts analysis for all exercises of jurisdiction (including in rem); he lacks sufficient contacts with California.	The court held Shaffer is limited to quasi in rem; Hood governs true in rem proceedings, so minimum-contacts over the owner are not required for in rem forfeiture when the court has jurisdiction over the res.
Whether venue in the Central District is proper under 28 U.S.C. § 1355(b)(1)(A)	Government: § 1355(b) permits venue where any acts or omissions giving rise to the forfeiture occurred, including acts by conspirators in the district.	Obaid: Venue requires acts in the district that directly relate to the forfeited res (i.e., narrower connection).	The court held venue proper: alleged conspiratorial acts in the Central District (including purchases traceable to the scheme) satisfied the relatively low § 1355(b) standard.

Shaffer v. Heitner, 433 U.S. 186 (1977) (held that jurisdictional assertions must meet International Shoe minimum-contacts standard; central to debate over in rem vs. quasi in rem)
Tennessee Student Assistance Corp. v. Hood, 541 U.S. 440 (2004) (bankruptcy discharge is in rem; court’s jurisdiction is premised on the res and need not have personal jurisdiction over absent creditors)
Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) (established minimum-contacts due-process test for personal jurisdiction)
United States v. Batato, 833 F.3d 413 (4th Cir. 2016) (applied Shaffer principles to civil forfeiture context; discussed state-based minimum-contacts approach)
LiButti v. United States, 178 F.3d 114 (2d Cir. 1999) (applied minimum-contacts analysis to determine in rem jurisdiction over a third-party claimant)
United States v. Approximately $1.67 Million in U.S. Currency, 513 F.3d 991 (9th Cir. 2008) (forfeiture is in rem; discusses jurisdictional focus on the res)
United States v. Ten Thousand Dollars in U.S. Currency, 860 F.2d 1511 (9th Cir. 1988) (applied traditional in rem principles in a forfeiture action)
Republic Nat. Bank of Miami v. United States, 506 U.S. 80 (1992) (recognizes valid seizure of the res as prerequisite to in rem civil forfeiture)