Shaffer v. Heitner
Citation: 433 U.S. 186 (U.S. Supreme Court, 1977)
Facts
Heitner, a shareholder of Greyhound Corporation, brought a derivative suit in Delaware against Greyhound and several of its officers and directors, alleging they had caused the corporation to engage in illegal activities. He obtained sequestration of the defendants’ stock in Greyhound (deemed to be located in Delaware by statute) to assert quasi in rem jurisdiction. The defendants had no other contacts with Delaware.
Issue
Whether a state may exercise quasi in rem jurisdiction over a defendant based solely on the presence of the defendant’s property in the state, without regard to the defendant’s other contacts with the forum.
Holding
The Supreme Court held that the minimum contacts analysis of International Shoe applies to all assertions of state court jurisdiction, including quasi in rem jurisdiction. Because the defendants had no meaningful contacts with Delaware, the exercise of jurisdiction was unconstitutional.
Rule
All forms of personal jurisdiction — in personam, in rem, and quasi in rem — must satisfy the minimum contacts test of International Shoe. The presence of property in the forum state alone is not sufficient to establish jurisdiction over the owner of that property unless the property is related to the claim or the owner otherwise has minimum contacts with the forum.
Significance
Shaffer unified all jurisdiction analysis under the International Shoe minimum contacts framework, ending the special category of property-based quasi in rem jurisdiction. It is the key case linking the territorial theory of Pennoyer to the modern due process framework.