University of Baltimore Law Review


In Rush v. Savchuk, the Supreme Court struck down the controversial Seider doctrine, which permitted a state to exercise jurisdiction over a nonresident defendant solely on the basis of his insurer doing business in that state. This Comment analyzes the development of in personam and quasi in rem jurisdiction and the constitutional principles that led to the Rush decision. The author concludes, in light of Rush, that direct action statutes against insurers would not withstand constitutional attack in cases in which the controversy at issue occurred outside the forum state and the tortfeasor was not otherwise subject to that state's jurisdiction.

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