The initial twenty-first century personal jurisdiction decisions from the Supreme Court reveal that personal jurisdiction doctrine has not changed much since the nineteenth century. The nomenclature has changed, realism has replaced formalism, some fictions purportedly have been discarded, and the adjudicatory reach of courts has somewhat expanded, but the doctrine retains the same conceptual core—the social contract philosophical tradition limiting the scope of governmental authority to those establishing the requisite relationship with the sovereign.
Charles W. "Rockey" Rhodes,
Nineteenth Century Personal Jurisdiction Doctrine in a Twenty-First Century World,
64 Fla. L. Rev.
Available at: https://scholarship.law.ufl.edu/flr/vol64/iss2/3