In Burnham v. Superior Court of California, the United States Supreme Court considered the continued vitality of transient jurisdiction. Although the Court unanimously held that the defendant was subject to state court jurisdiction, it failed to agree on the issue of transient jurisdiction, issuing three plurality opinions. This Note examines Burnham and concludes that the Court should invalidate transient jurisdiction as a violation of due process rights. It proposes that the Court evaluate all state court assertions of jurisdiction against a minimum contacts standard.
An Easy Case Makes Bad Law—Burnham v. Superior Court of California, 110 S. Ct. 2105 (1990),
66 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol66/iss2/9