However, the Court failed to produce a majority opinion, as the members were sharply divided on the reasons for the decision, reflecting two fundamentally different approaches to how due-process issues are to be analyzed.

At common law, recognized by the Supreme Court in Pennoyer v. Neff (1877), a civil action was commenced by serving process on the defendant within the forum jurisdiction.

In cases such as International Shoe Co. v. Washington and Shaffer v. Heitner, the Court had accepted that a non-resident served outside a state could still be subject to jurisdiction, but only where the defendant had "certain minimum contacts with it such that the maintenance of the suit does not offend 'traditional notions of fair play and substantial justice.'"

"[A] a doctrine of personal jurisdiction that dates back to the adoption of the Fourteenth Amendment and is still generally observed unquestionably meets th[e] standard" of due process.

Scalia also expresses serious disagreement with the idea of a defendant establishing jurisdiction by "[availing himself] of significant benefits provided by the State" because this would create an extremely vague and unclear standard.

Scalia asks about someone enjoying fifteen minutes worth of "benefits" (rather than the three days as in the actual case) as being sufficient, thus explaining why this proposed rule is exceptionally vague.

According to Justice Brennan, the Court's decision in Shaffer v. Heitner required that all methods of obtaining jurisdiction must be evaluated according to contemporary notions of due process.

Justice Brennan concluded that "[f]or these reasons, as a rule the exercise of personal jurisdiction over a defendant based on his voluntary presence in the forum will satisfy the requirements of due process."

In a short opinion concurring in part and concurring in the judgment, Justice White stated that "[t]he rule allowing jurisdiction to be obtained over a nonresident by personal service in the forum state, without more, has been and is so widely accepted throughout this country that I could not possibly strike it down, either on its face or as applied in this case, on the ground that it denies due process of law guaranteed by the Fourteenth Amendment."

In Justice White's view, while the Supreme Court has authority to strike down even traditional accepted procedures that do not provide due process, there was no basis for doing so in this case.

To avoid endless litigation, Justice White concluded that challenges to the fairness of jurisdiction based on service in individual cases need not be entertained, "[a]t least ... where presence in the forum state is intentional, which would almost always be the fact."