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To establish minimum contacts, the plaintiff cannot be the only link between the defendant and the forum. Rather, it is the defendant’s conduct that must form the necessary connection with the forum state that is the basis for its jurisdiction over him. To be sure, a defendant’s contacts with the forum state may be intertwined with his transactions or interactions with the plaintiff or other parties. But a defendant’s relationship with a plaintiff or third party, standing alone, is an insufficient basis for jurisdiction. Due process requires that a defendant be haled into court in a forum state based on his own affiliation with the state, not based on the random, fortuitous, or attenuated contacts he makes by interacting with other persons affiliated with the state.
Petitioner Walden, a Georgia police officer working as a deputized Drug Enforcement Administration agent at a Georgia airport, searched respondents and seized a large amount of cash. Respondents allege that after they returned to their Nevada residence, petitioner helped draft a false probable cause affidavit in support of the funds' forfeiture and forwarded it to a United States Attorney's Office in Georgia. In the end, no forfeiture complaint was filed, and respondents' funds were returned. Respondents filed a tort suit against petitioner in Federal District Court in Nevada. The District Court dismissed the suit, finding that the Georgia search and seizure did not establish a basis to exercise personal jurisdiction in Nevada. The Ninth Circuit reversed, holding that the District Court could properly exercise jurisdiction because petitioner had submitted the false probable cause affidavit with the knowledge that it would affect persons with significant Nevada connections.
Could the District Court of Nevada have personal jurisdiction over petitioner?
The Court held that because the agent had no other contacts with Nevada, and because a plaintiff’s contacts with the forum state could not be decisive in determining whether the defendant’s due process rights were violated, the court in Nevada was not allowed to exercise personal jurisdiction under these circumstances. In essence, the agent's relevant conduct in seizing the claimants' cash occurred entirely in Georgia, and the mere fact that his conduct affected the claimants with connections to the forum state did not suffice to authorize jurisdiction. The one-time interaction could not establish the minimum contact necessary with Nevada.