Pennoyer v. Neff
United States Supreme Court
95 U.S. 714 (1877)
Attorney J.H. Mitchell sued his client Neff (plaintiff) in Oregon state court for unpaid legal fees, but Neff was neither an Oregon resident nor personally served, receiving only published notice; after Neff failed to appear, Mitchell obtained a default judgment, and only afterward did Neff acquire an Oregon tract of land, which Mitchell had seized and sold at auction to satisfy the judgment, later assigning the land to Pennoyer (defendant). Neff sued Pennoyer to recover the property, and the lower federal court found Mitchell's underlying judgment invalid due to defects in the publication affidavit, prompting Pennoyer's appeal to the Supreme Court.
Whether a state court may exercise personal (in personam) jurisdiction over a nonresident defendant, sufficient to render a valid money judgment against him, based solely on published notice when the defendant owned no property in the state at the time the suit began.