Walden v. Fiore

Facts

Plaintiffs were detained at an airport in Puerto Rico by TSA agents. The TSA agents discovered nearly $97,000 in cash in one of Plaintiff Fiore’s carry-on bags. Plaintiffs explained that they were professional gamblers and had won the money at a San Juan casino. Plaintiffs were subsequently cleared for departure to Atlanta, Georgia, but law-enforcement officials in San Juan alerted a Drug Enforcement Administration (DEA) task force at the Atlanta airport to Plaintiffs’ impending arrival. Upon the plaintiffs’ arrival in Atlanta, Defendant and the task force approached Plaintiffs, questioned them about the source of the money, and used a drug-sniffing dog on Plaintiff Fiore’s bag. Although the dog did not find any narcotics on Plaintiff Fiore’s bag, Defendant seized the cash despite Plaintiff Fiore’s gambling explanation. Eventually, the money was returned to Plaintiffs. Plaintiffs filed suit against Defendant in federal district court in Nevada, seeking damages pursuant to Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S. 388 (1971). Plaintiffs alleged that after they returned to their Nevada residence, Defendant 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 Plaintiffs’ funds were returned. The district court granted Defendant’s motion to dismiss the complaint on the ground that the court did not have personal jurisdiction over Defendant. Plaintiffs appealed. A divided panel of the court of appeals reversed. The United States Supreme Court granted certiorari to review.