Limited and Special Appearances

“The Advisory Committee Note indicates that even though special appearances were abolished in Minnesota, limited appearances by which a defendant in a quasi in *633 rem action could defend to the extent of the property involved, without submitting personally to the jurisdiction of the court, were probably allowed. The purpose of the amendment quoted above was to abolish limited appearances, but is also recognizes the right of a defendant to challenge the jurisdiction of the court without submitting personally to its jurisdiction. Hence, in 1959, appellant could probably have defended on respondent's claim to the extent of the property attacked without submitting to the personal jurisdiction of the court. To appear merely to challenge the jurisdiction of the court in the quasi in rem action would be even less; hence she could not be said to have appeared generally.”

Hansen v. McAndrews, 183 N.W.2d 1, 5 (Wis. 1971)

“A special appearance should not be confused with a limited appearance. A special appearance is a procedural device, widely used in the United States, which enables the defendant to appear solely for the purpose of raising the jurisdictional question, and if so limited does not subject the defendant to the consequences of a general appearance. A limited appearance, on the other hand, seeks to avoid conversion of in rem jurisdiction into personal jurisdiction by defending the action on the merits. It enables the defendant to appear ‘for purposes of litigating the merits but limited to those claims which could be constitutionally adjudicated by the court in his absence by virtue of its in rem jurisdiction.’"

Book Review, New York Civil Practice, 112 U.Pa.L.Rev. 1222, 1230 (1963)

Every one of the other 25 cases produced in response to the search term “’special appearance’ /s ‘limited appearance’” conflated the two terms.