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Shaffer Et Al. v. Heitner

• 1976 • 433 U.S. 186 • Burger Court
In Shaffer v. Heitner, the U.S. Supreme Court ruled that a state cannot exercise jurisdiction over an individual or corporation based solely on their ownership of property within the state if they are not residents and have no other significant contacts with the state. The case involved Greyhound Corporation directors who were sued in Delaware where Greyhound was incorporated but none of them resided nor had any business activities there; their only connection to Delaware was through owning...Open Case
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Chief Burger Court
Term: 1976
Docket: 75-1812
433 U.S. 186
97 S. Ct. 2569
53 L. Ed. 2d 683
1977 U.S. LEXIS 139
Argued: Feb 22, 1977

Shaffer Et Al. v. Heitner

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Opinion Summary
AI Abstract

In Shaffer v. Heitner, the U.S. Supreme Court ruled that a state cannot exercise jurisdiction over an individual or corporation based solely on their ownership of property within the state if they are not residents and have no other significant contacts with the state. The case involved Greyhound Corporation directors who were sued in Delaware where Greyhound was incorporated but none of them resided nor had any business activities there; their only connection to Delaware was through owning stock in Greyhound which is considered personal property rather than real estate under Delaware law. The court held that such minimal contact did not satisfy due process requirements for establishing jurisdiction as outlined by International Shoe Co v Washington (1945). This decision significantly limited states' ability to assert long-arm jurisdiction over non-residents and corporations, requiring more substantial connections for legal proceedings.

Dissent Summary
AI Abstract

In the dissenting opinion for Shaffer v. Heitner, Justice William J. Brennan Jr., joined by Justices Byron White and Thurgood Marshall, argued that Delaware's sequestration statute was constitutional because it provided due process to defendants. They contended that the majority misinterpreted International Shoe Co. v Washington (1945) in requiring a minimum contact between defendant and forum state for personal jurisdiction; instead they believed this requirement only applied when a court exercised jurisdiction over an individual outside its territory without his consent or presence at trial initiation - which wasn't the case here as Greyhound Corporation had willingly incorporated under Delaware law thus consenting to its jurisdiction implicitly. The dissent also disagreed with majority’s view of property rights arguing that shares represented more than just contractual relationships but were indeed property within Delaware making them subject to local laws including sequestration statutes.

Opinion written by Justice TMarshall
Decided: Jun 24, 1977
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Argued: Oct 05, 2026
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