Walden v. Fiore

Facts of the Case

Petitioner Walden, a Georgia police officer working as a deputized Drug Enforcement Administration agent at a Georgia airport, searched respondents and seized a large amount of cash. Respondents allege that after they returned to their Nevada residence, petitioner helped draft a false probable cause affidavit in support of the funds’ forfeiture and forwarded it to a United States Attorney’s Office in Georgia. In the end, no forfeiture complaint was filed, and respondents’ funds were returned. Respondents filed a tort suit against petitioner in Federal District Court in Nevada. The District Court dismissed the suit, finding that the Georgia search and seizure did not establish a basis to exercise personal jurisdiction in Nevada. The Ninth Circuit reversed, holding that the District Court could properly exercise jurisdiction because petitioner had submitted the false probable cause affidavit with the knowledge that it would affect persons with significant Nevada connections.

Question

Does due process allow the Nevada court to exercise personal jurisdiction over Walden?Is the District of Nevada the place where a substantial part of the events or omissions giving rise to the claim occurred for purposes of establishing venue when all of defendant’s alleged acts or omissions happened in another district?

CONCLUSION

No, unanswered. Justice Clarence Thomas delivered the opinion for the unanimous Court. The Court held that the district court could not exercise personal jurisdiction over Walden because he lacked contacts with Nevada. The Due Process Clause of the Fourteenth Amendment requires that a non-resident defendant have a substantial connection with the state in which he is sued. This connection must arise from the contacts that the defendant himself creates