Shaffer v. Heitner
433 U.S. 186
PROCEDURAL HISTORY: Appellants, corporate officers and directors, sought review of judgment from the Supreme Court of Delaware 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 U.S. Const. amend. XIV.
FACTS: 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.
HOLDING:
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.
ANALYSIS:
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 any reason to expect to be brought before a Delaware court.
RULES:
-Property cannot be subjected to a court's judgment unless reasonable and appropriate efforts have been made to give the property owners actual notice of the action.
-Whether due process is satisfied must depend rather upon the quality and nature of the activity in relation to the fair and orderly administration of the laws which it was the purpose of the due process clause to insure. That clause does not contemplate that a state may make binding a judgment in personam against an individual or corporate defendant with which the state has no contacts, ties, or relations
CONCLUSION: The judgment was reversed as appellant's seized property did not have sufficient contacts with the state, and appellants neither purposefully availed themselves of the privilege of conducting activities within the state nor had any reason to expect to be brought before a Delaware court.
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433 U.S. 186
PROCEDURAL HISTORY: Appellants, corporate officers and directors, sought review of judgment from the Supreme Court of Delaware 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 U.S. Const. amend. XIV.
FACTS: 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.
HOLDING:
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.
ANALYSIS:
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 any reason to expect to be brought before a Delaware court.
RULES:
-Property cannot be subjected to a court's judgment unless reasonable and appropriate efforts have been made to give the property owners actual notice of the action.
-Whether due process is satisfied must depend rather upon the quality and nature of the activity in relation to the fair and orderly administration of the laws which it was the purpose of the due process clause to insure. That clause does not contemplate that a state may make binding a judgment in personam against an individual or corporate defendant with which the state has no contacts, ties, or relations
CONCLUSION: The judgment was reversed as appellant's seized property did not have sufficient contacts with the state, and appellants neither purposefully availed themselves of the privilege of conducting activities within the state nor had any reason to expect to be brought before a Delaware court.
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