Forget Pennoyer v. Neff: Apparently, We’re Serving Parties Through Instagram Now

February 13, 2018 Casey C. Sullivan

Every year, thousands of law students sit down to claw their way through Pennoyer v. Neff, the classic, if confounding, Supreme Court case. Dewy-eyed Civ-Pro students, they desperately try to separate issues of federalism from those of due process, to delineate in rem from quasi in rem from in personam jurisdiction, to untangle the procedural mess that was Pennoyer, in which Pennoyer himself played only the smallest of parts. Or they just grab a hornbook and read: Constructive service is insufficient to establish personal jurisdiction over parties outside the court’s territorial range.

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