The United States Court of Appeals, Second Circuit, in O'Connor v. Lee-Hy Paving Corp., upheld New York's insurance attachment procedure which serves as a vehicle for gaining personal jurisdiction over out-of-state defendants in causes of action that arise outside of New York. The court thereby determined that New York federal courts, in applying the procedures, had not violated defendant's due process because the minimum contacts requirement of the recent United Stated Supreme Court case, Shaffer v. Heitner, had been met.
Mackus, Eloise Lubbinge
"In Rem Jurisdiction; Attachment of Insurance Debts; State Statutes; O'Connorv. Lee-Hy Paving Corp.,"
Akron Law Review: Vol. 12
, Article 9.
Available at: http://ideaexchange.uakron.edu/akronlawreview/vol12/iss2/9