In the 1997 case of New Mexico, ex rel. Manuel Ortiz v. Timothy Reed, the U.S Supreme Court was asked to consider whether a state court could exercise jurisdiction over an out-of-state defendant based on that individual's relationship with an in-state plaintiff. The case involved a child custody dispute between two parents who lived in different states - New Mexico and Oklahoma. The mother (Ortiz) filed for divorce and sought custody of their son in New Mexico while the father (Reed) contested this action from his residence in Oklahoma. The central issue revolved around whether or not personal jurisdiction existed given that Reed had no significant contacts with New Mexico other than being married to someone living there and having a child who resided there part-time. Ultimately, the Supreme Court ruled against Ortiz stating that under existing precedents regarding interstate legal disputes, it would be inappropriate for courts in one state to assert authority over residents of another unless they have substantial connections within its borders beyond simply maintaining relationships with people living there.

The dissenting opinion in the case of New Mexico, ex rel. Manuel Ortiz v. Timothy Reed argued that the majority's decision to deny habeas corpus relief was incorrect because it failed to consider important factors regarding ineffective counsel and due process rights. The dissent believed that Ortiz’s Sixth Amendment right had been violated as his attorney did not adequately represent him during trial, failing to investigate or present crucial evidence which could have potentially changed the outcome of his case. Furthermore, they disagreed with the majority's interpretation of "prejudice" under Strickland v. Washington standard for ineffective assistance claims; arguing that there was a reasonable probability that but for counsel’s unprofessional errors, result would have been different at trial phase or sentencing stage.