On April 6, 2023, a federal judge dismissed most claims in Amazon’s lawsuit over alleged kickbacks tied to Northern Virginia properties for planned AWS data centers—but not the entire case. Tortious-interference and civil-conspiracy claims continued against specified defendants. The ruling was a summary-judgment decision, not a verdict that resolved every allegation. The Fourth Circuit later issued an opinion on selected issues in the appeal, on September 16, 2025.
What was Amazon’s lawsuit about?
Amazon.com, Inc. and Amazon Data Services, Inc. sued former Amazon real-estate transaction managers and outside real-estate developers over transactions connected with planned AWS data centers in Northern Virginia. The district court described eleven commercial property transactions: nine leases and two direct purchases, including purchases known as White Peaks and Blueridge.
Amazon alleged that the defendants arranged kickbacks and inflated property costs, including through transactions involving Northstar Commercial Partners. Those claims were allegations, not findings that every defendant committed wrongdoing. The defendants denied the allegations; GeekWire reported that former manager Carl Nelson characterized his post-employment arrangements as consulting work. The case was Amazon.com, Inc. v. WDC Holdings LLC, No. 1:20-cv-484, in the U.S. District Court for the Eastern District of Virginia, Alexandria Division. (April 6, 2023 court order; GeekWire’s April 2023 report)
Which claims were dismissed, and which survived?
Judge Rossie D. Alston Jr. granted summary judgment in part and denied it in part. The order directed judgment for defendants on Amazon’s RICO, fraud, breach-of-contract, detinue, unjust-enrichment, and conversion claims. It allowed tortious interference to proceed against the Watson defendants and civil conspiracy to proceed against the Nelson defendants, Casey Kirschner, and the Watson defendants. The conspiracy claim against attorney Rodney Atherton was dismissed, and all claims against him were terminated.
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| Claim or issue | April 6, 2023 disposition | Defendants covered |
|---|---|---|
| RICO | Judgment for defendants | As directed in the order’s defendant-by-defendant disposition |
| Fraud | Judgment for defendants | As directed in the order’s defendant-by-defendant disposition |
| Breach of contract | Judgment for defendants | As directed in the order’s defendant-by-defendant disposition |
| Detinue | Judgment for defendants | As directed in the order’s defendant-by-defendant disposition |
| Unjust enrichment and constructive trust | Judgment for defendants | As directed in the order’s defendant-by-defendant disposition |
| Conversion and constructive trust | Judgment for defendants | As directed in the order’s defendant-by-defendant disposition |
| Tortious interference with contractual or business relations | Allowed to proceed | Watson defendants |
| Civil conspiracy | Allowed to proceed | Nelson defendants, Casey Kirschner, and Watson defendants |
| Civil conspiracy | Dismissed; all claims against this defendant terminated | Rodney Atherton |
The order addressed eight counts, some of which combined a claim with a constructive-trust theory. Its conclusions specify outcomes by defendant and claim; describing the ruling as simply “seven claims thrown out” would obscure that some theories continued against some defendants. (Court order, Document 1376)
Why did some claims continue?
The court concluded that the remaining tortious-interference claim could provide the underlying wrongful act needed for the civil-conspiracy theory. On that basis, tortious interference continued against the Watson defendants, and conspiracy continued against the Watson defendants, the Nelson defendants, and Kirschner.
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The court ruled for Atherton on the conspiracy claim. It found that he acted in a representative capacity for clients and that the record did not show an agreement between him and the Watson defendants. That ruling ended the case against him. The court’s different outcomes reflected the legal and evidentiary record for particular claims and parties; they should not be reduced to a single explanation. GeekWire noted that insufficient evidence of financial damages was a recurring issue for claims Amazon sought to take to trial, while the order addressed the claims individually.
What did the ruling mean—and not mean?
Summary judgment is a decision made by a judge on the evidentiary record and applicable law, without a trial on the claims resolved that way. For claims that survived, the judge did not decide that the alleged misconduct had been proved. The ruling narrowed Amazon’s case: it won no final judgment on the surviving claims at that stage, and defendants won judgment on the claims the order dismissed.
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Amazon said after the decision, “We remain confident in pursuing the case given the extensive amount of evidence,” according to GeekWire. Amy Nelson, a lawyer and Carl Nelson’s spouse, described the decision as “very fair, very well thought-out.” Those were the parties’ reactions, not findings by the court. (GeekWire)
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What happened on appeal?
The U.S. Court of Appeals for the Fourth Circuit issued an opinion on September 16, 2025, addressing selected parts of Amazon’s appeal. The appellate opinion records that the district court had entered judgment on RICO, fraud, breach-of-contract, detinue, unjust-enrichment, and conversion claims while allowing tortious-interference and some conspiracy theories to proceed. Amazon appealed selected rulings, including RICO, fraud, unjust enrichment, conversion, and Atherton’s civil-conspiracy liability. (Fourth Circuit opinion, No. 23-1991; official court listing)
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The available appellate sources establish that an opinion was issued on those selected issues, but do not establish the ultimate disposition of the claims that had continued in district court. The 2023 order therefore should not be treated as proof that the whole lawsuit ended, and the later appeal alone does not establish that the remaining claims have since been tried, settled, or otherwise concluded.
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