In Walden v. Fiore, the U.S. Supreme Court ruled on a jurisdictional issue related to an incident where a Georgia police officer confiscated $97,000 in gambling winnings from professional gamblers while they were at an Atlanta airport en route back to their home in Nevada. The couple sued the officer in Nevada for violating their Fourth Amendment rights but the question was whether or not Nevada had jurisdiction over this case since all actions by the defendant took place in Georgia. The court unanimously held that because none of his actions connected him to Nevada and he did not create meaningful contacts with that state, it lacked jurisdiction over him under due process clause of Fourteenth Amendment which requires minimum contact between defendant and forum state before personal jurisdiction can be exercised.

In the dissenting opinion for Walden v. Fiore, Justice Sonia Sotomayor argued that the majority's decision was too narrow in its interpretation of personal jurisdiction and did not adequately consider modern realities of travel and commerce. She contended that because the defendant had knowingly targeted residents of Nevada with his actions, he should reasonably expect to be held accountable there. The fact that these actions occurred while the plaintiffs were temporarily in Georgia does not negate their connection to Nevada or make it unfair for him to face legal proceedings there. Furthermore, she expressed concern about potential implications on future cases involving internet-based interactions where physical location may be less clear-cut.