Home › Case briefs › Civil Procedure

Walden v. Fiore

Supreme Court of the United States · 2014 · Civil Procedure

Civil ProcedurePersonal JurisdictionSpecific Jurisdictionminimum contactsspecific jurisdictionintentional tortsCalder effects testdefendant-focused inquiry

Facts

Petitioner, a Georgia police officer working as a deputized DEA agent at the Atlanta airport, questioned respondents during a layover, seized nearly $97,000 in cash from them in Georgia, and later helped draft and forward an allegedly false probable cause affidavit in Georgia to a United States Attorney's Office in Georgia. Respondents had told authorities they had connections to Nevada and were traveling to Las Vegas. After the seizure, respondents' Nevada attorney contacted petitioner in Georgia and sent documentation supporting the legitimacy of the funds. No forfeiture complaint was filed, and the DEA later returned the funds to respondents in Nevada.

Issue

Whether due process permits Nevada courts to exercise specific personal jurisdiction over a Georgia defendant whose allegedly tortious conduct occurred entirely in Georgia, based solely on his knowledge that the plaintiffs had connections to Nevada and would allegedly suffer harm there.

Rule

For specific jurisdiction, the defendant's suit-related conduct must create a substantial connection with the forum State itself. The inquiry is defendant-focused: a plaintiff's contacts with the forum, or the mere fact that a plaintiff experiences injury there, cannot by themselves supply the necessary minimum contacts. In intentional-tort cases, jurisdiction requires intentional conduct by the defendant that connects him to the forum, not just to a forum resident.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Chicago, Illinois, airport security officer Marcus Doyle seized $48,000 from Priya Desai during a domestic layover. Priya told Marcus she lived in Phoenix, Arizona and needed the money for her business there, but Marcus never contacted Arizona, sent any documents there, or took any action outside Illinois.

If Priya sues Marcus in Arizona for the allegedly unlawful seizure, is Arizona's exercise of specific personal jurisdiction most likely proper?

Explanation. Specific jurisdiction requires that the defendant's own suit-related conduct create a substantial connection with the forum State. Here, Marcus acted entirely in Illinois, and his knowledge that Priya lived in Arizona and would feel injury there does not create contacts with Arizona itself. The majority opinion rejects relying on the plaintiff's forum ties and foreseeable in-forum injury alone. Physical presence is not required, but some defendant-created contact with the forum is.