Shaffer v. Heitner
United States Supreme Court
433 U.S. 186 (1977)
Heitner (plaintiff) brought a shareholder derivative suit in Delaware against individual Greyhound directors (represented by Shaffer, defendant) over conduct occurring in Oregon, and sought an ex parte sequestration order against the directors' Greyhound stock, treating the suit as quasi in rem (traditionally justified by mere presence of property in the jurisdiction rather than actual contacts between the defendant and the state); the directors challenged the sequestration as violating due process, but the Delaware courts upheld it based on the property's statutory location in the state.
Whether there must be sufficient contacts between the state and the interests of the defendants in the property seized before a court can exercise jurisdiction quasi in rem.