Back to the Future: The Revival of \u3cem\u3ePennoyer\u3c/em\u3e in Personal Jurisdiction Doctrine and the Demise of \u3cem\u3eInternational Shoe\u3c/em\u3e
This Article argues that the Court’s recent decisions have effectively revived Pennoyer’s focus on physical presence and status, at the expense of the fairness and contact considerations set forth in International Shoe, as the bases for asserting personal jurisdiction. Part II details the jurisdictional analysis under both Pennoyer and International Shoe. Part III discusses the evolution of personal jurisdiction doctrine under International Shoe. Part IV demonstrates that the Court’s recent decisions have revitalized Pennoyer’s territorially based regime, and consequently diminished the thrust of International Shoe
