1. Shaffer v. Heitner The Temporary Triumph of Fairness over History

2. Chronology International Shoe1945 McGee1957 Hanson1958 Shaffer1977 World Wide VW1980 Helicopteros1984 Burger King1985 Asahi1987 Burnham1990

3. Post-Shaffer Uses for QIR Can only be used where long arm or general could be used Sometimes useful where personal service on D (even outside the state) is difficult or impossible. Sometimes useful to fill in starfish gaps.

4. Your Case Constitutional Limit Statutory Limit

5. Burnham The Possible Triumph of History over Fairness

6. Burnham: Which Key? Transient Jurisdiction Domicile Jurisdiction Consent Jurisdiction Long-Arm Jurisdiction General Jurisdiction

7. Burnham Fact Map Married in W. Va. H & W move to NJ H&W separate H&W agree that W would file irreconcilable differences divorce W moves to CA

8. Burnham Lawsuit Chart H files for divorce (desertion) in NJ W files for divorce (ID) in CA H travels to CA on business & visits kids W serves H in CA

9. Conflicting Judicial Approaches Beyond Liberal vs. Conservative Nationalism vs. States Rights Pro-Plaintiff vs. Pro-Defendant Expansive vs. Narrow View of Due Process Protections Static (Historical) vs. Dynamic (Current Fairness) View of Due Process