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Supreme Court rules contacts with forum state not decisive for personal jurisdiction

The US Supreme Court [official website] ruled [opinion, PDF] unanimously Tuesday in Walden v. Fiore [SCOTUSblog backgrounder] that when the conduct of the defendant, a Georgia police officer, occurred entirely in Georgia, the mere fact that his conduct affected plaintiffs with connections to Nevada does not authorize jurisdiction over him in Nevada. The decision overturns the US Court of Appeals for the Ninth Circuit [official website], which concluded [opinion] that the Constitution permitted courts in Nevada to exercise jurisdiction over a deputized Drug Enforcement Administration (DEA) agent who lived and worked in Georgia and seized money from a pair of Nevada gamblers connecting through the Atlanta airport. Gina Fiore and Keith Gipson were traveling to Nevada. They were searched in a layover in Atlanta, Georgia, where their money was seized as evidence of drug transactions. The money was actually legal gambling winnings, but Fiore and Gipson sued the Georgia law enforcement agent in Nevada. The Supreme Court granted certiorari to determine whether due process permits a Nevada court to exercise jurisdiction in this case. Citing Rush v. Savchuck [opinion], the court ruled that no matter how significant plaintiff's contacts with the forum may be, those contacts cannot be "decisive in determining whether the defendant's due process rights are violated." Moreover, the minimum contacts test looks to the defendant's contacts with the forum state itself, not the defendant's contacts with persons who reside there. Justice Clarence Thomas delivered the opinion of the court.

The Supreme Court heard oral arguments [JURIST report] for the case in November. Counsel for Walden argued that the "plaintiff-centered approach is inconsistent with this Court's precedence which emphasize that the defendant himself must have meaningful contacts with the forum State." The Court granted certiorari [JURIST report] in May.

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