Civil Procedure — personal jurisdiction — minimum contacts

Listen to this article

U.S. Supreme Court

Civil

Civil Procedure — personal jurisdiction — minimum contacts

Even though a defendant knew his allegedly tortious conduct in Georgia would delay the return of funds to plaintiffs with connections to Nevada, Nevada courts lacked personal jurisdiction over the defendant.

Petitioner lacks the “minimal contacts” with Nevada that are a prerequisite to the exercise of jurisdiction over him. No part of petitioner’s course of conduct occurred in Nevada, and he formed no jurisdictionally relevant contacts with that forum. The Ninth Circuit reached its contrary conclusion by improperly shifting the analytical focus from petitioner’s contacts with the forum to his contacts with respondents, obscuring the reality that none of petitioner’s challenged conduct had anything to do with Nevada itself. Respondents emphasize that they suffered the “injury” caused by the delayed return of their funds while residing in Nevada, but Calder made clear that mere injury to a forum resident is not a sufficient connection to the forum. The proper question is whether the defendant’s conduct connects him to the forum in a meaningful way: Here, respondents’ claimed injury does not evince such a connection. The injury occurred in Nevada simply because that is where respondents chose to be when they desired to use the seized funds. Other possible contacts noted by the Ninth Circuit—that respondents’ Nevada attorney contacted petitioner in Georgia, that cash seized in Georgia originated in Nevada, and that funds were returned to respondents in Nevada— are ultimately unavailing.

688 F. 3d 558, reversed.

12-574 Walden v. Fiore

Thomas, J.