In Walden v. Fiore (2014) 571 U.S. the United States Supreme Court readdressed the personal jurisdiction analysis for intentional torts. In that case, the plaintiffs, who were residents of California and Nevada, sued a Georgia police officer in federal court in Nevada for an intentional tort based on actions undertaken by the police officer while serving as a deputized Drug Enforcement Administration agent in Georgia. At the Atlanta airport, the police officer had seized cash carried by the plaintiffs while they were in transit from Puerto Rico to Las Vegas. The police officer moved the cash to a secured location, and, at some point, helped to draft an affidavit, which the plaintiffs claimed was false, to show probable cause for forfeiture of the funds and forwarded that affidavit to the United States Attorney's office in Georgia. All of the police officer's actions took place in Georgia, none took place in Nevada, where the plaintiffs filed suit, yet the Ninth Circuit Court of Appeals upheld personal jurisdiction on the ground the police officer "'expressly aimed'" his submission of the false affidavit at Nevada, knowing that doing so would affect persons with a "'significant connection'" with that state. The United States Supreme Court held that due process did not permit the court in Nevada to exercise personal jurisdiction over the police officer. The court confirmed that 0 "for a State to exercise jurisdiction consistent with due process, the defendant's suit-related conduct must create a substantial connection with the forum State." The court emphasized two concepts related to this principle. "First, the relationship must arise out of contacts that the 'defendant himself' creates with the forum State." The plaintiff's contacts with the forum "cannot be 'decisive.'" (Ibid.) "Second, our 'minimum contacts' analysis looks to the defendant's contacts with the forum State itself, not the defendant's contacts with persons who reside there." (Ibid.) The defendant's conduct "must form the necessary connection with the forum State that is the basis for its jurisdiction over him." (Ibid.) The Walden court explained those principles apply when intentional torts are involved and used Calder as an illustration of such application. After reviewing the nature of the contacts in Calder, the Supreme Court concluded: "The crux of Calder was that the reputation-based 'effects' of the alleged libel connected the defendants to California, not just to the plaintiff. The strength of that connection was largely a function of the nature of the libel tort. However scandalous a newspaper article might be, it can lead to a loss of reputation only if communicated to (and read and understood by) third persons. . Accordingly, the reputational injury caused by the defendants' story would not have occurred but for the fact that the defendants wrote an article for publication in California that was read by a large number of California citizens. Indeed, because publication to third persons is a necessary element of libel citation, the defendants' intentional tort actually occurred in California. . In this way, the 'effects' caused by the defendants' article--i.e., the injury to the plaintiff's reputation in the estimation of the California public--connected the defendants' conduct to California, not just to a plaintiff who lived there. That connection, combined with the various facts that gave the article a California focus, sufficed to authorize the California court's exercise of jurisdiction." The defendants in Calder "'expressly aimed'" their intentional conduct at California because they knew the National Enquirer had its largest circulation in California and the article would "'have a potentially devastating impact' there." The Supreme Court in Walden applied those principles to conclude the police officer lacked the minimal contacts with Nevada to support personal jurisdiction. It was undisputed that no part of the defendant's course of conduct occurred in Nevada; the defendant "never traveled to, conducted activities within, contacted anyone in, or sent anything or anyone to Nevada." "In short, when viewed through the proper lens--whether the defendant's actions connect him to the forum--petitioner formed no jurisdictionally relevant contacts with Nevada."