In the 1914 U.S. Supreme Court case Kirmeyer v. State of Kansas, the court upheld a state law that allowed for the seizure and sale of out-of-state property to satisfy debts owed by non-residents in Kansas. The plaintiff, Kirmeyer, was an Oklahoma resident who owned cattle located in Kansas which were seized and sold to pay his debt under this law. He argued that this violated his Fourteenth Amendment rights as he had not been personally served notice within the state's jurisdiction. The Supreme Court disagreed with Kirmeyer’s argument stating that due process does not always require personal service within a state's jurisdiction if there is another way to provide reasonable notification about legal proceedings related to their property held in another state. In this case, it was found sufficient that notices were posted at public places where cattle auctions took place and published in local newspapers. This ruling affirmed states' authority over properties within their borders even when those assets belong to non-residents while also clarifying what constitutes adequate notice under due process requirements.

In the dissenting opinion for Kirmeyer v. State of Kansas, Justice Holmes disagreed with the majority's ruling that a state law requiring foreign corporations to consent to being sued in local courts as a condition of doing business within the state was constitutional. He argued that such laws violated due process rights and were essentially coercive, forcing companies into an unfair choice between surrendering their rights or losing access to important markets. Furthermore, he contended that these laws could lead to states engaging in retaliatory legislation against each other’s businesses which would be detrimental for interstate commerce overall. Thus, he believed this decision contradicted previous rulings where similar conditions imposed by states were deemed unconstitutional.