947 357 us at 251 25354 upon an analogy of choice of

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947 357 U.S. at 251, 253–54. Upon an analogy of choice of law and forum non conveniens , Justice Black argued that the relationship of the nonresident defen- dants and the subject of the litigation to the Florida made Florida the natural and constitutional basis for asserting jurisdiction. 357 U.S. at 251, 258–59. The Court has numerous times asserted that contacts sufficient for the purpose of designating a particular state’s law as appropriate may be insufficient for the purpose of assert- ing jurisdiction. See Shaffer v. Heitner, 433 U.S. 186, 215 (1977); Kulko v. Superior Court, 436 U.S. 84, 98 (1978); World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 294–95 (1980). On the due process limits on choice of law decisions, see Allstate Ins. Co. v. Hague, 449 U.S. 302 (1981). 2006 AMENDMENT 14—RIGHTS GUARANTEED
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The Court continued to apply International Shoe principles in diverse situations. Thus, circulation of a magazine in a state was an adequate basis for that state to exercise jurisdiction over an out- of-state corporate magazine publisher in a libel action. The fact that the plaintiff did not have “minimum contacts” with the forum state was not dispositive since the relevant inquiry is the relations among the defendant, the forum, and the litigation. 948 Or, damage done to the plaintiff’s reputation in his home state caused by circulation of a defamatory magazine article there may justify assertion of juris- diction over the out-of-state authors of such article, despite the lack of minimum contact between the authors (as opposed to the publish- ers) and the state. 949 Further, though there is no per se rule that a contract with an out-of-state party automatically establishes juris- diction to enforce the contract in the other party’s forum, a franchi- see who has entered into a franchise contract with an out-of-state corporation may be subject to suit in the corporation’s home state where the overall circumstances (contract terms themselves, course of dealings) demonstrate a deliberate reaching out to establish con- tacts with the franchisor in the franchisor’s home state. 950 The Court has continued to wrestle over when a state may ad- judicate a products liability claim for an injury occurring within it, at times finding the defendant’s contacts with the place of injury to be too attenuated to support its having to mount a defense there. In World-Wide Volkswagen Corp. v. Woodson , 951 the Court applied its “minimum contacts” test to preclude the assertion of jurisdic- tion over two foreign corporations that did no business in the fo- rum state. Plaintiffs had sustained personal injuries in Oklahoma in an accident involving an alleged defect in their automobile. The car had been purchased the previous year in New York, the plain- tiffs were New York residents at time of purchase, and the accident had occurred while they were driving through Oklahoma on their way to a new residence in Arizona. Defendants were the automo- bile retailer and its wholesaler, both New York corporations that did no business in Oklahoma. The Court found no circumstances
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