A lawsuit filed in the wrong state gets thrown out for lack of jurisdiction.
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A lawsuit filed in the wrong state gets thrown out for lack of jurisdiction.
Why it matters
In Wambui v. Sanders, Todd, and Reiman, the U.S. District Court for the District of Oregon dismissed the case brought by plaintiff Elias Wambui against a Washington State judge, a Washington deputy prosecuting attorney, and a Washington attorney. The court found it had no personal jurisdiction over the defendants because all three defendants live in Washington, all relevant events occurred in Washington, and the plaintiff failed to allege any meaningful contacts between the defendants and Oregon.
Who it affects
This ruling directly affects self-represented litigants who file federal lawsuits in a state where the events and defendants have no meaningful connection. It reinforces that plaintiffs must sue in a court that has legal authority over the defendants, regardless of where the plaintiff lives.
What happens next
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Decision issued Aug 21, 2026
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- Decision issued Aug 21, 2026
- Possible rehearingParties can ask the same court to reconsider.
- Possible appeal to the circuit court
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Aug 21, 2026
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DEEPER READ
Elias Wambui, representing himself, sued three individuals connected to proceedings that arose from a traffic stop and car seizure in Kittitas County, Washington. He brought federal civil rights claims against a Washington State judge, a Washington deputy prosecuting attorney, and a Washington attorney. All three defendants moved to dismiss the case, arguing that an Oregon federal court had no authority over them. Wambui did not respond to that motion. The central legal question was whether the Oregon court had personal jurisdiction over defendants who live and work in Washington. Personal jurisdiction comes in two forms: general jurisdiction, which applies when a defendant is essentially at home in the forum state, and specific jurisdiction, which applies when the defendant has minimum contacts with the forum state and the lawsuit arises from those contacts. The court found neither form of jurisdiction applied here. On general jurisdiction, all three defendants are Washington citizens, and Wambui made no allegation that any of them had continuous or systematic contact with Oregon. On specific jurisdiction, the court explained that the focus must be on contacts the defendants themselves created with Oregon, not simply on where the plaintiff happened to live. Because the traffic stop, the car seizure, and all other relevant events took place in Washington, and because the defendants had no alleged ties to Oregon, there were no minimum contacts to support jurisdiction. The court granted the defendants' motion to dismiss. There was no dissent, as this is a single-judge district court ruling. The opinion does not address whether Wambui could refile the case in a court with proper jurisdiction, such as a Washington court.
CITATION AND RECORD
Record source: CourtListener
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON ELIAS WAMBUI, Case No. 3:26-cv-567-SI Plaintiff, ORDER v. PAUL R. SANDERS, PATRICIA TODD, and AARON REIMAN, in their personal and official capacities, Defendants. Michael H. Simon, District Judge. Plaintiff Elias Wambui, representing himself, has sued Washington State Judge Paul R. Sanders, Washington States Deputy Prosecuting Attorney Patricia Todd, and attorney Aaron Reiman, asserting several federal civil rights claims. Plaintiff alleges that he was stopped for speeding by local law enforcement officers in Kittitas County, Washington, and that his car was subsequently seized. Defendants, who all reside in the state of Washington, have moved to dismiss the lawsuit on the grounds that the Court lacks personal jurisdiction under Rule 12(b)(2) of the Federal Rules of Civil Procedure. Plaintiff did not respond to the motion to dismiss. Because all events relevant to this controversy took place in Washington and Defendants are not “at home” in Oregon, the Court grants Defendants’ motion to dismiss. In a motion to dismiss for lack of personal jurisdiction under Rule 12(b)(2), the plaintiff bears the burden of proving that the court’s exercise of jurisdiction is proper. Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797, 800 (9th Cir. 2004). When resolving such a motion on written materials alone, a court need “only inquire into whether the plaintiff’s pleadings and affidavits make a prima facie showing of personal jurisdiction.” Id. (cleaned up). Although a plaintiff may not rest solely “on the bare allegations of its complaint, uncontroverted allegations in the complaint must be taken as true.” Id. (quotation mark and citation omitted). “There are two forms of personal jurisdiction that a forum state may exercise over a nonresident defendant—general jurisdiction and specific jurisdiction.” Boschetto v. Hansing, 539 F.3d 1011, 1016 (9th Cir. 2008).1 “For an individual, the paradigm forum for the exercise of general jurisdiction is the individual’s domicile . . . .” Goodyear Dunlop Tire Operations, S.A. v. Brown, 564 U.S. 915, 924 (2011). Otherwise, a court has general jurisdiction over a defendant whose contacts with the forum are “continuous and systematic,” even if those contacts are wholly unrelated to the plaintiff’s claims. Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 415-16 (1984). If the court lacks general personal jurisdiction, it may have 1 A federal statute does not govern personal jurisdiction here, so the Court applies Oregon law to determine whether the exercise of personal jurisdiction is appropriate. Boschetto, 539 F.3d at 1015. Oregon’s long-arm statute is co-extensive with constitutional standards. Gray & Co. v. Firstenberg Mach. Co., 913 F.2d 758, 760 (9th Cir. 1990). Thus, the Court need only determine whether its exercise of personal jurisdiction over Defendants would offend constitutional due process requirements. See Boschetto, 539 F.3d at 1015; Oregon ex rel. Hydraulic Servocontrols Corp. v. Dale, 294 Or. 381, 384 (1982). This inquiry requires the Court to consider the “quality and nature of the activity in relation to the fair and orderly administration of the laws which it was the purpose of the due process clause to insure.” Int’l Shoe Co. v. Washington, 326 U.S. 310, 319 (1945). specific personal jurisdiction if the defendant has certain minimum contacts with the forum state, the controversy arose out of those contacts, and the exercise of jurisdiction is reasonable. See Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472-77 (1985); Boschetto, 539 F.3d at 1016. The Court lacks personal jurisdiction over Defendants. There is no general jurisdiction because Defendants are citizens of Washington and Plaintiff fails plausibly to allege that Defendants had any contact with the state of Oregon. Helicopteros, 466 U.S. at 415-16. Plaintiff’s failure to allege any contacts between Defendants and Oregon also forecloses the exercise of specific jurisdiction, because Plaintiff has failed plausibly to allege that Defendants had “minimum contacts” with the state. Burger King, 471 U.S. at 472-77. Although Plaintiff lived in Portland at the time of the incident, “[t]he inquiry whether a forum State may assert specific jurisdiction over a nonresident defendant focuses on the relationship among the defendant, the forum, and the litigation.” Axiom Foods, Inc. v. Acerchem Int’l, Inc., 874 F.3d 1064, 1068 (9th Cir. 2017) (quoting Walden v. Fiore, 571 U.S. 277, 287 (2014)). This means that “the relationship must arise out of contacts that the ‘defendant himself’ creates with the forum State.” Walden, 571 U.S. at 284 (emphasis in original) (quoting Burger King, 471 U.S. at 475). On the face of the Complaint, drawing all inferences in Plaintiff’s favor, Defendants have no relevant contacts with Oregon. The Court GRANTS Defendants’ motion to dismiss, ECF 14. IT IS SO ORDERED. DATED this 21st day of August, 2026. /s/ Michael H. Simon Michael H. Simon United States District Judge
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