When a cause of action is transitory in nature the plaintiff may sue on it in any state where he can obtain personal jurisdiction over the defendant. And when personal jurisdiction is not available, he can often, by process of garnishment or attachment, obtain jurisdiction quasi in rem and proceed with the trial of the issue. The judgment so obtained is not binding on the defendant in personam but it may bind the defendant's property or the debt to him from a third party. In Hobbs v. Lewis a plaintiff sought to make use of garnishment for this purpose. He claimed certain sums were due him from the United Mine Workers of America Welfare and Retirement Fund, and brought garnishment proceedings against the Tennessee Products & Chemical Corporation to attach $3,500 owed by it to the Fund.
John W. Wade,
Conflict of Laws -- 1955 Tennessee Survey,
8 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vlr/vol8/iss5/4