M1 Walden v. Fiore (2013) Case Summary

Walden v. Fiore (2013)

Case Summary

I. Which courts had jurisdiction and what were their respective rulings?

1.    The Nevada Federal District Court:

The Nevada Federal District Court ruled that because the seizure took place in and aimed at Georgia, the Nevada Court was deprived of personal jurisdiction.

Or: The Nevada Federal District court ruled that it did not have personal jurisdiction over the case, because the seizure took place in Georgia and aimed at Georgia.

2.    The Ninth Circuit U.S. Court of Appeals:

The Ninth Circuit reversed the decision, on the basis that Walden had drafted a false probable cause affidavit with the knowledge that his action would harm Nevada residents.

3.    The U.S.S.C

Walden filed a petition for a writ of certiorari to the USSC to determine whether or not the Nevada District court could exercise personal jurisdiction over the case and whether or not it was the appropriate venue.

II. Brief outline of the Facts:

Walden and Fiore are professional gamblers returning from San Juan, Puerto Rico to their home in Las Vegas, Nevada, via Altlanta, Georgia.

At Atlanta Airport, Fiore and Gipson were controlled by Anthony Walden and DEA Agents / were subjected to a ramped-up security screening.

Grammar: To be subject to ≠ to be subjected to

A drug-sniffing dog / a drug-detection dog was alerted to Gipson’s bag / reacted to Gipson’s bag and a substantial amount of cash ($97,000) was found in Fiore’s and Gipson’s carry-on bags, which their claimed constituted personal gambling winnings.

On suspicion that the money resulted from illicit drug activity, the agents seized the cash, promising to return it once Fiore and Walden had produced paperwork proving it had been acquired legitimately.

Once they had returned to Vegas / Upon returning to Vegas, Fiore and Gipson did so, but Walden nonetheless submitted a false probable cause affidavit to the U.S. Attorney for the Northern District of Georgia to initiate a forfeiture action. 

Approximately seven months after the seizure, an Assistant U.S. Attorney determined that the government lacked probable cause to seize / forfeit Fiore and Gipson’s money, and returned it to them.

Gipson and Fiore then decided to sue Walden / initiate a tort action against Walden, alleging the seizure constituted a violation of their Fourth Amendment rights.  

III. What did the plaintiffs allege in their suit against the defendant?

Fiore and Gipson argue that the Nevada District court has personal jurisdiction over the case as the defendant, Walden, intentionally targeted them, as individuals, to suffer in Nevada (although Walden himself is from Georgia and his action took place in Georgia). The harm caused by Walden’s false affidavit occurred in Nevada, and so Nevada should have personal jurisdiction.

They contend that when defendants know that the plaintiffs will feel the effects of the defendants’ actions in a different jurisdiction, states’ sovereignty requires that the state where the plaintiff feels the injury be able to assert personal jurisdiction over the defendant.

They believe that Walden’s intentional conduct towards residents of Nevada tie him to the state.

Vocabulary: to tie a defendant to a state

Walden’s arguments:

On the other hand, one of Walden’s arguments consisted in saying that the Ninth Circuit’s decision to grant Nevada personal jurisdiction would have drastic consequences for federal law-enforcement officers (and federal employees) that were required to interact with people from all over the United-States in the course of their work. Indeed, pursuant to the Ninth’s circuit standard, federal law-enforcement officers could be potentially sued by plaintiffs in states where they had no dealings whatsoever.

IV. What was the decision handed down here? When can a court exercise personal jurisdiction over the parties to a civil action?

The issue the United States Supreme Court will consider in Walden v. Fiore is twofold. It will both examine:

a.    Whether a state can exercise personal jurisdiction over a defendant whose sole contact with the state is his knowledge that the plaintiff had connections to the state.

b.    Supposing that Nevada may exercise jurisdiction over the case, it must then decide whether Nevada is a proper venue.

While Walden claims that because the action that gave rise to the claim took place in Georgia, Nevada is not the proper venue, Fiore, on the other hand, purports that because Walden’s action targeted Nevada residents, Nevada is the proper venue.

The court’s decision stems from / proceeds from / results from its interpretation of the test articulated in Calder v Jones, according to which personal jurisdiction is determined by three conditions:

1.    Whether the defendant committed an intentional act

2.    Whether the act was aimed at the forum state

3.    Whether the harm caused would be experienced in the forum state.

The Supreme Court ruled that the Nevada District Court lacked personal jurisdiction over the case, because Walden did not have “minimal contacts” / “minimum contacts” with the forum State. Indeed, the defendant did not purposefully directed his conduct at the forum, but only at its residents. 

In Calder, on the other hand, California had personal jurisdiction over defendants from Florida because California was “the focal point” of both the story the defendants had presented in their article (at the origin of the case) and of the harm suffered.

A defendant’s contacts with a state are to be distinguished from his / her contacts with the state’s plaintiffs.

Summary in “Plain English” (from Scotusblog):

It is a basic principle of jurisdiction that you cannot force somebody to travel to a far-off place to litigate a case if they have no connection to that place.  If you want to sue somebody in a particular state, you need to show that they have made contact with the state — either by committing an act in that state, or at least by intentionally reaching out to the state somehow.  But you cannot sue them simply because you live in the state and you have been hurt.  Because Officer Walden confiscated the plaintiffs’ money in Georgia and kept it in Georgia, they could not sue him in Nevada when they returned home.

Sources for this summary include The Cornell University Law School website and Scotusblog.com