The landmark decision of Shaffer v. Heitner spelled out important constitutional limitations on the exercise of quasi-in-rem jurisdiction, but has nonetheless generated doubts and perplexity in its judicial aftermath. The author argues that the ultimate importance of Shaffer may relate less to its specific holdings regarding quasi-in-rem jurisdiction than to its broader perspective of attributing a constitutional dimension to the classical doctrine of the more convenient forum.
Stefan A. Riesenfeld,
Shaffer v. Heitner: Holding, Implications, Forebodings,
30 Hastings L.J. 1183
Available at: https://repository.uclawsf.edu/hastings_law_journal/vol30/iss4/8