Note on Assignment re In Rem Jurisdiction

Recall the three bases of personal jurisdiction that the Supreme Court in Pennoyer v. Neff found to be constitutional: (1) appearance (consent); (2) personal service on one within the territory of the sovereign when served; and (3) attachment of property within the territory of of the sovereign at the commencement of the action.

At first reading, Shafer v. Heitner seems to nullify basis #3. Does it? Read the Shafer opinion carefully to identify the possibilities for jurisdiction based on #3, consistent with the opinion. We will explore them through hypos in class.