25 February 2014

Law in Plain English: Walden v. Fiore

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

SCOTUSblogWalden v. Fiore

Argument: Nov 4 2013 (Aud.)

Background: Fiore and Gipson gambled in Puerto Rico and won $97,000. They intended to travel to Las Vegas via Atlanta, but were stopped and questioned at the San Juan Airport. TSA agents eventually let them go, but told them they might be questioned later in the trip. In Atlanta, DEA Agent Walden approached and questioned them. A drug-detection dog alerted, and Walden seized the cash. Fiore and Gipson continued on to Las Vegas. The cash was later returned when the Assistant U.S. Attorney concluded that the government lacked probable cause. Fiore and Gipson sued Walden in Nevada under Bivens, alleging that Walden violated their Fourth Amendment rights when he seized their cash in Georgia. The District Court dismissed the complaint for lack of personal jurisdiction, but the Ninth Circuit reversed.

Issue: The questions before the Court are (1) whether due process permits a court (in this case, in Nevada) to exercise personal jurisdiction over a defendant (Walden) whose sole “contact” with the forum state is his knowledge that the plaintiff has connections to that state; and (2) whether the judicial district where the plaintiff suffered injury is a district “in which a substantial part of the events or omissions giving rise to the claim occurred” for purposes of establishing venue even if the defendant’s alleged acts and omissions all occurred in another district.

Holding: In a unanimous opinion, the Supreme Court ruled that the District Court lacked jurisdiction. For a State to exercise jurisdiction consistent with due process, a relationship among the defendant, the forum, and the litigation must arise out of contacts that the defendant himself creates with the forum. The plaintiff cannot be the only link between the defendant and the forum. As a result, the District Court could not hear Fiore and Gipson's claim.
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