The decision of Shaffer v. Heitner marks a significant departure from established principles concerning in rem jurisdiction. No longer may a court take jurisdiction of a lawsuit merely by sequestering any property of the defendant that happens to be located in that state.
Milligan, Richard S.
"In Rem Jurisdiction; Due Process; Minimum Contacts; State Statutes; Shaffer v. Heitner,"
Akron Law Review: Vol. 11
, Article 5.
Available at: https://ideaexchange.uakron.edu/akronlawreview/vol11/iss2/5