Rogers v. City of Hobart, Indiana

Dist. Ct. did not err in dismissing for lack of personal jurisdiction plaintiff's section 1983 and related Illinois state court actions, alleging that defendants-Indiana city and police official had subjected plaintiff to unreasonable seizure, when defendant-officer: (1) had mistakenly identified plaintiff as individual who had intimidated confidential informant; and (2) had taken actions that eventually led to plaintiff's arrest in Illinois and then release next day after error had been discovered. Dist. Ct. lacked personal jurisdiction over both defendants, where neither defendant had any meaningful contacts with Illinois, since: (1) in course of his duties, officer simply accessed database available to him to determine fairly basic biographical information on plaintiff; (2) officer simply entered existence of arrest warrant that officer had obtained from Indiana court into another database available to Illinois officials; and (3) all of officer's actions took place in Indiana and none of his actions were specifically aimed at Illinois in his efforts to arrest plaintiff. Fact that information officer procured from database was information plaintiff had given to Illinois Secretary of State or that officer had obtained arrest warrant for individual living in Illinois did not require different result.