"The decision of Intermeat, Inc. v. American Poultry, Inc. is the first decision rendered by a federal appeals court based on the United States Supreme Court decision of Shaffer v. Heitner. The Shaffer Court handed down a landmark decision in 1977 that appeared at first light to aim the principles of quasi in rem jurisdiction in a new direction. From the date of the decision it appeared that a court could no longer take jurisdiction of a lawsuit based merely on the fact that property of the defendant was located in the state in which the suit was filed. However, in applying the holding of Shaffer to the Intermeat lawsuit, it seems that the decision in Shaffer is not as sweeping as the legal community first thought."
Frisby, John D. Jr.
"Quasi In Rem Jurisdication; Minimum Contacts; State Statutes; Intermeat, Inc. v. American Poultry, Inc.,"
Akron Law Review: Vol. 12
, Article 8.
Available at: http://ideaexchange.uakron.edu/akronlawreview/vol12/iss2/8