Some issues to consider when reading Shaffer v. Heitner
 

                         1) What is a shareholder derivative action?

                         2) Were limited appearances possible under the Delaware statute at issue in Shaffer?

                         3) What about quasi in rem jurisdiction with respect to real (as opposed to intangible and
                         personal) property? Would that satisfy Int'l Shoe analysis?

                         4) What about Justice Stevens's argument that all that is necessary for due process is that one
                         who owns property in the forum state was made aware of the possibility that quasi in rem
                         jurisdiction could be asserted over him as a result of this ownership?

                         5) Even without quasi in rem jurisdiction, aren't there enough Int'l Shoe contacts between the
                         defendants and Delaware to allow for personal jurisdiction? 

                         6) Consider the following case: A former wife who has moved to California from their home
                         state of Massachusetts with the consent of the former husband sues him for child support in
                         California state court. He makes a motion to dismiss for lack of personal jurisdiction. What
                         result? Is there anything else you need to know to answer this question?