University of Richmond UR Scholarship Repository Law Faculty Publications School of Law 1987 Sin, Scandal and Substantive Due Process: Personal Jurisdiction and Pennoyer Reconsidered Wendy Collins Perdue University of Richmond,
[email protected] Follow this and additional works at: http://scholarship.richmond.edu/law-faculty-publications Part of the Civil Procedure Commons, and the Jurisdiction Commons Recommended Citation Wendy Collins Perdue, Sin, Scandal and Substantive Due Process: Personal Jurisdiction and Pennoyer Reconsidered, 62 Wash. L. Rev. 479 (1987) This Article is brought to you for free and open access by the School of Law at UR Scholarship Repository. It has been accepted for inclusion in Law Faculty Publications by an authorized administrator of UR Scholarship Repository. For more information, please contact
[email protected]. SIN, SCANDAL, AND SUBSTANTIVE DUE PROCESS: PERSONAL JURISDICTION AND PENNOYER RECONSIDERED Wendy Collins Perdue* "Confusion now hath made its masterpiece," 1 exclaims Macduff in Act II of Macbeth. The same might be said of the venerable case, Pennoyer v. Neff.2 Over 100 years after issuing Pennoyer the Supreme Court is still laboring to articulate a coherent doctrine of personal jurisdiction within the framework established by that opinion. Recently, the Court has become particularly interested in personal jurisdiction and has dealt with the issue seven times in the last four years. 3 Yet despite this growing body of case law, the doctrinal underpinnings remain elusive. The Court continues to treat geographic boundaries as central to the interests protected by personal jurisdiction, but has never satisfactorily explained why they are so central or what interest the doctrine of personal jurisdiction is intended to protect.