A state may exercise jurisdiction over an absent defendant only if the defendant has certain minimum contacts with the forum such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.
Plaintiff claimant was riding in a car operated by defendant insured and was injured in a car accident in Indiana. Plaintiff, a Minnesota resident, brought an action for negligence in a Minnesota state court against defendant, an Indiana resident. Since defendant had no contacts with Minnesota that would support in personam jurisdiction, plaintiff sought to obtain quasi in rem jurisdiction by garnishing the contractual obligation of defendant’s insurer licensed to do business in Minnesota. The trial court held in plaintiff’s favor. The Supreme Court of Minnesota affirmed the trial court’s judgment. The Supreme Court of the United States reversed the state supreme court’s decision.
Could a state exercise quasi in rem jurisdiction over a defendant who had no forum contacts by attaching the contractual obligation of an insurer licensed to do business in the state to defend and indemnify him in connection with the suit.
The only affiliating circumstance offered to show a relationship among defendant insured, Minnesota, and the lawsuit was that defendant's insurance company did business in the state. However, the fictional presence in Minnesota of State Farm's policy obligation to defend and indemnify defendant could not be deemed to give the State the power to determine defendant's liability for the out-of-state accident.