Personal Jurisdiction

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7^th Circuit Court of Appeals

Case Name: Cortez Javan Rogers v. City of Hobart, Indiana, et al.,

Case No.: 20-2919

Officials: RIPPLE, HAMILTON, and KIRSCH, Circuit Judges.

Focus: Personal Jurisdiction 

Hobart police officers, relying on information obtained from an investigative database, misidentified Appellant Cortez Javan Rogers as the person who allegedly had intimidated a witness in a pending murder case. Mr. Rogers shares a first and last (though not middle) name with another person who was the actual subject of the officers’ search. Based on the information found in an investigative database, the Hobart officers applied for an arrest warrant and, upon obtaining a warrant from an Indiana judge, placed it in a database accessible to police departments in other states. A Chicago police officer later had an encounter with Mr. Rogers and, upon checking the outstanding warrants database, learned of the outstanding Indiana warrant. The officer then arrested Mr. Rogers. Chicago authorities immediately released him upon discovery that the Indiana warrant misidentified the suspect.

Mr. Rogers then brought this action in the United States District Court for the Northern District of Illinois against the City of Hobart, the Hobart Police Department, and Sergeant Rod Gonzalez, its lead investigator. The defendants moved to dismiss for lack of personal jurisdiction. The district court granted the motion. We now affirm the district court’s judgment. The Hobart officers did not purposefully engage in any activity in Illinois or direct any action in Illinois that would cause them to reasonably anticipate that they would be haled into the courts of that State. Moreover, the exercise of personal jurisdiction over them would offend traditional notions of fair play and substantial justice. Simply put, none of the supposed Illinois contacts asserted by Mr. Rogers, whether considered separately or together, constitute the requisite “minimum contacts” among the State, the defendants, and the cause of action necessary to fulfill the requirements of due process. Furthermore, to subject Indiana law enforcement officers to the jurisdiction of another state’s courts under these circumstances would be fundamentally unfair.

Affirmed

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Derek A Hawkins is Associate Corporate Counsel, IP at Amazon.