Milliken v. Meyer
Citation and Court
311 U.S. 457 (1940), Supreme Court of the United States
Facts
Meyer, a Wyoming domiciliary, was served in Colorado under Wyoming’s long-arm statute permitting substituted service on domiciliaries who are absent from the state. Meyer appeared specially to challenge jurisdiction, arguing that service outside Wyoming’s borders was ineffective to confer personal jurisdiction.
Issue
Whether a state may exercise personal jurisdiction over one of its domiciliaries by substituted service of process made outside its territory.
Holding
Domicile alone is a sufficient basis for a state to exercise personal jurisdiction over an individual, and service by mail on a domiciliary outside the state satisfies due process so long as it is reasonably calculated to give actual notice.
Rule / Doctrine
A state has a strong interest in adjudicating the affairs of its domiciliaries and imposing obligations on them as part of the mutual benefits and burdens of domicile. Domicile is an independent and sufficient basis for personal jurisdiction, distinct from physical presence or consent, and is not defeated by the domiciliary’s temporary absence when served outside the state’s borders.
Significance
Milliken v. Meyer establishes domicile as one of the traditional bases for personal jurisdiction — alongside physical presence, consent, and citizenship. It is taught alongside Pennoyer v. Neff and the International Shoe line as defining the pre-modern and modern frameworks for in personam jurisdiction.