Washington Law Review


A shareholder in Greyhound Corporation, a Delaware corporation, brought a derivative action against corporate officers and directors alleging that certain actions by the defendants in Oregon had caused substantial harm to the corporation. The suit was initiated in a Delaware state court with jurisdiction based only on the statutory presence of property in that state. The defendants contested this attempt to assert quasi in rem jurisdiction on due process and other grounds, but their arguments were rejected by the trial court and the Delaware Supreme Court. The United States Supreme Court reversed. Held: The minimum contacts test developed in International Shoe Co. v. Washington must be applied to evaluate the assertion of jurisdiction by a state court; the contacts in this case were insufficient to sustain the court's jurisdiction. Shaffer v. Heitner, 433 U.S. 186 (1977).

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