Walden v. Fiore
134 S. Ct. 1115
| SCOTUS | 2014Background
- Walden, a Georgia police officer and DEA agent, seized cash from Fiore and Gipson at Atlanta airport.
- Walden helped draft a probable-cause affidavit in Georgia and forwarded it to a Georgia U.S. Attorney; no forfeiture complaint was filed and the funds were returned.
- Fiore and Gipson, Nevada residents, sued Walden in Nevada federal court under Bivens for Fourth Amendment violations.
- District Court dismissed for lack of personal jurisdiction, relying on Calder v. Jones to hold Walden’s Georgia conduct did not justify Nevada jurisdiction.
- Ninth Circuit reversed, holding Nevada could exercise jurisdiction based on Walden’s alleged knowledge that the false affidavit would affect Nevada residents.
- Supreme Court reversed the Ninth Circuit, holding the Nevada court lacked personal jurisdiction because Walden had no relevant contacts with Nevada.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Nevada may exercise jurisdiction over Walden. | Fiore argues Walden’s conduct targeted Nevada via the false affidavit and harmed Nevada residents. | Walden contends no contacts with Nevada and no act in Nevada; due process requires defendant-initiated forum contacts. | No; Nevada lacks specific jurisdiction. |
| Whether a plaintiff’s forum-related injury suffices for jurisdiction. | Fiore claims foreseeable Nevada injury supports jurisdiction. | Walden argues injury to a forum resident is insufficient without defendant’s forum-related contacts. | No; injury alone is insufficient. |
Key Cases Cited
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (minimum contacts and fair play limitations on jurisdiction)
- International Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts necessity for in-personam jurisdiction)
- Keeton v. Hustler Magazine, Inc., 465 U.S. 770 (1984) (defendant-focused minimum contacts; forum contacts must arise from defendant)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (defendant’s own contacts with forum essential)
- Calder v. Jones, 465 U.S. 783 (1984) (forum connections based on effects of tort; publication-focused)
- Rush v. Savchuk, 444 U.S. 320 (1980) (plaintiff’s forum contacts cannot drive jurisdiction)
- Hanson v. Denckla, 357 U.S. 235 (1958) (contacts with forum must be defendant’s own)
- Daimler AG v. Bauman, 134 S. Ct. 746 (2014) (limits on general and specific jurisdiction in federal courts)