In a recent decision, the Supreme Court extended the requirement of minimum contacts for assertions of in personam jurisdiction to assertions of in rem and quasi in rem jurisdiction. The Court recognized that historical justifications for basing jurisdiction on the mere presence of property within the jurisdiction were no longer viable. The author argues that although the case was properly decided, the decision may prove difficult to apply and casts serious doubt on previously settled areas of law.
Shaffer v. Heitner-The Demise of Quasi In Rem Jurisdiction?,
32 U. Miami L. Rev.
Available at: http://repository.law.miami.edu/umlr/vol32/iss3/7