This Note proposes to examine the nature of United States contacts availed of by foreign defendants, and to determine the impact of Shaffer on the potential assertion of quasi-in-rem jurisdiction based on those contacts. It is instructive to consider quasi-in-rem jurisdiction's relation to four possible scenarios involving a foreign defendant: (1) the foreign defendant who owns real estate in this country; or (2) maintains deposits in United States banks; or (3) invests in securities that are registered locally; or (4) extends credit to United States companies or individuals on a regular basis. This Note ultimately concludes that in light of the narrow fact situation litigated in Shaffer, the high degree of contacts required for jurisdiction over an American defendant will necessarily be lower when determining the due process limitations of quasi-in-rem jurisdiction over foreign defendants characterized by the aforementioned hypothetical scenarios.
Steven H. Becker,
The Applicability of Shaffer to the Quasi-in-Rem Attachment of Foreigners' Assets,
12 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vjtl/vol12/iss2/9