Walden v. Fiore

188 L. Ed. 2d 12 · Supreme Court of the United States · 2014

Facts

Petitioner Walden, a Georgia police officer, seized cash from respondents Fiore and Gipson at the Atlanta airport. Respondents, Nevada residents, alleged Walden later drafted a false probable cause affidavit in Georgia, delaying the return of their funds. They sued Walden in Nevada federal court, which dismissed for lack of personal jurisdiction, but the Ninth Circuit reversed.

Issue

Can a Nevada court exercise personal jurisdiction over a Georgia police officer whose alleged tortious conduct (drafting a false affidavit) occurred entirely in Georgia but affected plaintiffs known to have connections to Nevada?

Holding

The Supreme Court held that the District Court lacked personal jurisdiction over the petitioner. The defendant's conduct did not create sufficient contacts with Nevada to establish jurisdiction, thus reversing the Ninth Circuit's decision.

Rule

Specific personal jurisdiction requires the defendant's conduct to create a substantial connection with the forum state itself, not merely with the plaintiff or third parties residing there. A plaintiff's contacts or mere injury in the forum state are insufficient to establish jurisdiction over an out-of-state defendant.

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Case brief last reviewed 2026-04-18. Prepared by CaseReader from the published opinion.