Grove Press, Inc. v. Central Intelligence Agency

Summary

The Second Circuit reviewed an interlocutory appeal concerning personal jurisdiction over former CIA officials sued for alleged surveillance, mail opening, wiretapping, and related activities. The court reversed the district court's reliance on 28 U.S.C. § 1391(e) and remanded for determination of personal jurisdiction under New York's long-arm statute, N.Y.C.P.L.R. § 302.

Holdings

1. Section 1391(e) did not provide a sufficient basis to sustain the district court's exercise of personal jurisdiction over the appellants in the circumstances presented, as controlled by Blackburn v. Goodwin.
2. The case was remanded to the district court to determine whether personal jurisdiction over the defendants existed under N.Y. C.P.L.R. § 302.

Questions Presented

1. Whether 28 U.S.C. § 1391(e) supplied a basis for personal jurisdiction over the former federal officials sued individually.
2. Whether the district court should determine personal jurisdiction under New York's long-arm statute, N.Y. C.P.L.R. § 302.

Disposition

reversed_and_remanded