Civil ProcedurePersonal jurisdiction
Walden v. Fiore
Supreme Court of the United States · Decided February 25, 2014
Full citation
Walden v. Fiore, 571 U.S. 277 (2014).
VerifiedQuotes, pinpoints and citation checked word for word against the opinion; facts checked against the opinion before publication. October 20, 2026.
Walden
police officerpetitioner
Fiore et al.
travelers whose cash was seizedrespondents
Brief
Facts
Walden was a police officer in Covington, Georgia. He also worked at the Atlanta airport as a deputized agent of the Drug Enforcement Administration (DEA). In August 2006, Transportation Security Administration agents searched Gina Fiore and Keith Gipson in San Juan, Puerto Rico, and found almost $97,000 in cash. Fiore told agents there that they had been gambling and had residences in California and Nevada, though they provided only California identification. When they reached Atlanta to catch a flight to Las Vegas, Walden questioned them at the departure gate, and Fiore said they were professional gamblers. After a drug-sniffing dog performed a sniff test, he seized the cash. He told them the money would be returned if they later proved a legitimate source. Their Nevada attorney then called Walden and sent him documents about the funds. Walden also helped draft an affidavit to show probable cause for forfeiture (the government's taking of the money) and sent it to a United States attorney's office in Georgia. Fiore and Gipson alleged that the affidavit was false and misleading because it misrepresented the airport encounter and left out exculpatory (pointing toward innocence) information. No forfeiture complaint was filed, and the DEA returned the funds in March 2007. No part of Walden's conduct took place in Nevada.
Issue
Does due process allow a federal court in Nevada to exercise personal jurisdiction over a Georgia officer whose allegedly tortious conduct occurred entirely in Georgia, when he knew the plaintiffs had Nevada connections and would feel the harm there?
Holding
A Nevada court may not exercise personal jurisdiction over Walden. His relevant conduct occurred entirely in Georgia. That he knew his conduct would affect plaintiffs with Nevada connections, and that they felt the harm there, does not create the needed contacts with Nevada.
IRAC
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