## Facts

- Gina Fiore and Keith Gipson, professional gamblers with residences in Nevada and California, traveled with nearly $97,000 in cash.
- TSA agents in Puerto Rico found the cash and notified law enforcement; a DEA task force in Atlanta was alerted that Fiore and Gipson were flying through Atlanta to Las Vegas.
- In Atlanta, Anthony Walden, a Georgia officer serving as a deputized DEA agent, stopped and questioned them and seized the cash after a drug-sniffing dog did not alert.
- After Fiore and Gipson returned to Nevada, Walden allegedly drafted a false probable-cause affidavit in Georgia and sent it to the U.S. Attorney’s Office in Georgia to support forfeiture.
- No forfeiture complaint was filed, and the money was returned.
- Fiore and Gipson filed a Bivens action in federal court in Nevada alleging Fourth Amendment violations based on the seizure and the allegedly false affidavit.

## Issues

1. Whether due process permits Nevada to exercise specific personal jurisdiction over a Georgia defendant when all relevant conduct occurred in Georgia and the only asserted Nevada link is the plaintiffs’ Nevada connections and resulting injury there.

## Decision

- The Supreme Court unanimously reversed the Ninth Circuit.
- Nevada lacked specific personal jurisdiction over Walden because he created no jurisdictionally relevant contacts with Nevada.
- Walden’s alleged conduct—seizure of cash and preparation of the affidavit—occurred entirely in Georgia, and the plaintiffs’ Nevada connections could not supply the necessary forum link.
- The case was remanded for proceedings consistent with the absence of personal jurisdiction.

## Legal Principles

- Specific personal jurisdiction must arise out of contacts the defendant himself creates with the forum State; the plaintiff cannot be the only link between the defendant and the forum.
- The minimum-contacts inquiry examines the defendant’s contacts with the forum State itself, not merely the defendant’s contacts with persons who reside there.
- Mere injury to a forum resident, without forum-directed conduct by the defendant, is insufficient to establish minimum contacts.
- An “effects” theory of jurisdiction requires conduct connecting the defendant to the forum State; foreseeability that a plaintiff will feel harm in the forum, by itself, does not satisfy due process.

## Conclusion

The Court held that due process barred Nevada from exercising specific personal jurisdiction over an out-of-state officer whose relevant acts occurred in Georgia, because the plaintiffs’ Nevada residence and in-forum effects of an out-of-forum seizure did not constitute defendant-created contacts with Nevada.


Walden v. Fiore, 571 U.S. 277 (2014)