## Facts

- Jeffrey D. Savchuk was injured as a passenger in a single-car accident near Elkhart, Indiana, allegedly caused by driver Randal Rush’s negligence.
- At the time of the accident, both Savchuk and Rush were Indiana residents; the vehicle was insured under a liability policy issued in Indiana by State Farm Mutual Automobile Insurance Co.
- Savchuk later moved to Minnesota and sued Rush in Minnesota state court for damages arising from the Indiana accident.
- Rush had no relevant contacts with Minnesota: he resided in Indiana, the accident occurred in Indiana, the insurance policy was issued in Indiana, and he owned no property in Minnesota.
- To obtain quasi in rem jurisdiction, Savchuk used Minnesota garnishment procedures to attach State Farm’s contractual obligation to defend and indemnify Rush, relying on State Farm’s business operations in Minnesota.
- Rush was served in Indiana; State Farm appeared in Minnesota as garnishee and contested any attachable obligation under Minnesota law.
- Minnesota trial and appellate courts upheld jurisdiction; after a remand for reconsideration under modern due process standards, the Minnesota Supreme Court again sustained jurisdiction based on the insurer’s in-state presence and obligation.

## Issues

1. Whether due process permits a state to exercise quasi in rem jurisdiction over a nonresident defendant with no forum contacts by attaching the in-state contractual obligations of the defendant’s insurer to defend and indemnify.
2. Whether an insurer’s forum contacts and in-state amenability to process may be attributed to the insured to satisfy the minimum-contacts requirement.
3. Whether treating an insurance obligation as property “present” in the forum can supply constitutionally sufficient contacts when the underlying tort and defendant are out of state.

## Decision

- The Supreme Court reversed in a 7–2 decision.
- The Court held that a state may not constitutionally exercise quasi in rem jurisdiction over a defendant who has no forum contacts by attaching the contractual obligation of an insurer licensed to do business in the forum to defend and indemnify the defendant in the suit.
- The Court rejected Minnesota’s attempt to base jurisdiction on the insurer’s in-state activities and on a deemed in-state situs of the insurer’s obligation.
- The Court concluded that the proceeding, though labeled quasi in rem, sought to adjudicate Rush’s personal liability and therefore required constitutionally sufficient contacts between Rush and Minnesota.

## Legal Principles

- All assertions of state-court jurisdiction, including quasi in rem jurisdiction, must satisfy the minimum-contacts requirement: jurisdiction is proper only when the defendant has contacts with the forum such that suit there is consistent with traditional notions of fair play and substantial justice.
- The due process inquiry centers on the relationship among the defendant, the forum, and the litigation; a third party’s forum contacts generally cannot be imputed to the defendant to establish jurisdiction.
- Legal fictions assigning a situs to intangible obligations (such as a debt or insurance duty) cannot substitute for the defendant’s purposeful forum affiliations when the forum seeks to determine the defendant’s out-of-state tort liability.
- Jurisdictional rules must provide predictability and avoid exposing defendants to suit in any state solely because an insurer or similar entity conducts business there.

## Conclusion

The Court held that Minnesota lacked jurisdiction because Rush had no contacts with the state and the insurer’s in-state presence and attachable obligations could not constitutionally supply the required connection between Rush, Minnesota, and the Indiana accident.


Rush v. Savchuk, 444 U.S. 320 (1980)