SHAFFER ET AL. v. HEITNER, 433 U.S. 186

Summary

Appellants, corporate officers and directors, sought review of judgment in appellee's shareholder derivative suit, contending that Delaware's statute permitting courts of that state to take jurisdiction of a lawsuit by sequestering defendant's property located in the state violated the due process clause of the Fourteenth Amendment, U.S. Const. amend. XIV, as it permitted state courts to exercise jurisdiction despite the absence of sufficient contacts with the state. On appeal, judgment was reversed. In support of its ruling, the court held that the minimum contacts test of International Shoe should have been applied to assertions of in rem as well as in personam jurisdiction. The court noted that appellant's seized property did not have sufficient contacts with the state to support Delaware's assertion of jurisdiction over appellants. The court further held that appellants had neither purposefully availed themselves of the privilege of conducting activities within the state, nor had ...