Civil Litigation,
9th U.S. Circuit Court of Appeals
Oct. 13, 2020
9th Circuit wades into the bog of in rem jurisdiction
The court recently wrestled with in rem jurisdiction issues in a civil forfeiture case, and the law remains far from clear.
Donald M. Falk
Partner
Schaerr Jaffe LLP
Phone: (415) 562-4942
Fax: (650) 331-4530
Email: dfalk@schaerr-jaffe.com
UC Berkeley Boalt Hall
Donald is a partner in the firm's Supreme Court and appellate practice. He is based in Palo Alto.
Remember struggling with Pennoyer v. Neff, 95 U.S. 714 (1878), in your first weeks of law school, and following the winding road of the Supreme Court's personal jurisdiction precedents up to the present day? The route that produced the modern minimum contacts tests for general and specific jurisdiction over a person has a sidestreet: in rem jurisdiction over a res, or thing, where a co...
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