In any case, jurisdictional issues can make or break a claim. Whether you're bringing a claim as an individual, or on behalf of your business, it is important to understand just how personal jurisdiction may shape your claims. We've discussed these issues briefly in the past, but last month the United States Supreme Court issued a decision we think illustrates just how nuanced and critical personal jurisdiction issues can be.
The case, Walden v. Fiore, 12-574, 2014 WL 700098 (U.S. Feb. 25, 2014), deals with a DEA agent who seized a large amount of cash from Nevada residents as they passed through a Georgia airport. After they returned to Nevada, the residents believe the DEA agent filed a false report justifying probable cause for the seizure. The Nevada residents then chose to bring a claim alleging just that in the Federal District Court of Nevada.
Recall when we discussed jurisdiction before, we pointed out persons bringing a claim involving acts in multiple different states can usually use jurisdiction to their advantage - picking the most convenient location, or where laws are most advantageous to the person bringing the claim. This case reminds us, however, there are certain restrictions that come with choosing that jurisdiction.
One such restriction is the "sufficient minimum contacts" doctrine. This doctrine allows a person to bring a claim in one state, regardless of whether the injury occurred in that state. The person making the claim just has to show the defendant had sufficient contact with the state where the claim is brought.
Through a number of appeals, the lower courts in Walden wrestled with whether Nevada was the appropriate jurisdiction for the claim. The Ninth Circuit justified it was because the DEA agent knew his actions would impact Nevada residents, and acting with this knowledge constituted sufficient minimum contacts with Nevada. Ultimately, however, the Unites States Supreme Court disagreed. The Supreme Court clarified that injury to a person from another state is not enough to establish minimum contacts with that state, even if the person causing the injury knew the victims were from that state. If the injury had occurred in Nevada, or the DEA agent engaged in some other kind of contact with Nevada, that conduct may have been a basis for establishing personal jurisdiction there.
Establishing personal jurisdiction can be difficult, as this case Supreme Court decision illustrates. Different circumstances, however, may give you a number of different options as to where to bring your claim. If you're wondering whether you have these options, you should contact a local attorney who can work through the nuances of personal jurisdiction with you to determine the best place to bring your claim.