Pennsylvania's foreign attachment procedures were held to be an unconstitutional violation of due process by the United States Court of Appeals for the Third Circuit. This note analyzes the evolving concept of due process in its relation to summary seizures and places the instant decision within that framework. The author attempts to evaluate the court's attack of the attachment statute's constitutionality based on a balancing test for procedural due process as well as the concurring opinion's contention that a minimum contacts test should replace quasi in rem jurisdiction.
James S. Carmichael,
Foreign Attachment Power Constrained-An End to Quasi In Rem Jurisdiction?,
31 U. Miami L. Rev.
Available at: http://repository.law.miami.edu/umlr/vol31/iss2/9