Pennoyer v. Neff
"Pennoyer v. Neff" is a landmark Supreme Court case decided in 1877 that addressed the principles of jurisdiction in civil law. The case arose when a plaintiff in Oregon sought to secure judgment in a contract dispute against a noncitizen and nonresident defendant. The plaintiff attempted to establish jurisdiction by attaching the defendant's real property through constructive service via a local newspaper notice. However, the Supreme Court, in an 8-1 decision, ruled that this method was insufficient for asserting jurisdiction over a defendant who was not physically present in the state. The Court articulated that a state possesses jurisdiction only over individuals and entities within its borders, a principle that presented challenges as transportation and communication evolved in the twentieth century.
"Pennoyer v. Neff" laid the groundwork for later cases, such as "International Shoe Co. v. Washington" and "Burnham v. Superior Court," which modified the earlier rigid jurisdictional standards. The ruling emphasized the limitations of state power in asserting jurisdiction over out-of-state parties, a concept that has significant implications for modern legal practice and corporate law.
Pennoyer v. Neff
Date: January 21, 1878
Citation: 95 U.S. 714
Issue: Diversity jurisdiction
Significance: The Supreme Court established the basic rules covering people who were not citizens or residents of states.
To secure judgment in a contract suit, a plaintiff in Oregon attached the real property of a noncitizen, nonresident of Oregon by constructive service through a legal notice in a local newspaper. By an 8-1 vote, the Supreme Court ruled against the plaintiff, holding that these steps were insufficent to secure jurisdiction over the defendant. The Court ruled that a state had jurisdiction over those within its borders and none over those outside its borders. This simple distinction became unworkable in the twentieth century because of modern transportation and communications and its failure to provide a basis for jurisdiction over corporations. International Shoe Co. v. Washington (1945) and Burnham v. Superior Court (1990) contain significant modifications. Justice Stephen J. Field wrote the opinion for the Court, and Justice Ward Hunt dissented.
