Walden v. Fiore

Gina Fiore and Keith Gipson (plaintiffs), residents of both California and Nevada, were detained at an airport in Puerto Rico by Transportation Security Administration (TSA) agents. The TSA agents discovered nearly $97,000 in cash in one of Fiore’s carry-on bags. The plaintiffs explained that they were professional gamblers and had won the money at a San Juan casino. The 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 the plaintiffs’ impending arrival. Anthony Walden (defendant), a police officer, was a member of the DEA task force. Upon the plaintiffs’ arrival in Atlanta, Walden and the task force approached the plaintiffs, questioned them about the source of the money, and used a drug-sniffing dog on Fiore’s bag. Although the dog did not find any narcotics on Fiore’s bag, Walden seized the cash despite Fiore’s gambling explanation. Eventually, the money was returned to the plaintiffs. The plaintiffs filed suit against Walden in federal district court in Nevada, seeking damages pursuant to Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S. 388 (1971). The district court granted Walden’s motion to dismiss the complaint on the ground that the court did not have personal jurisdiction over Walden. The plaintiffs appealed. A divided panel of the court of appeals reversed. The United States Supreme Court granted certiorari to review.