The case emerged from a dispute regarding a parcel of land, which now includes portions of Forest Park near downtown Portland, Oregon, secured by settler Marcus Neff.

Pennoyer was extremely embittered by the process, and carried his hatred for the Supreme Court into his political career.

The legal issues of the case turned on whether the court in question could extend personal jurisdiction over a defendant who isn't present in the state.

The Supreme Court's decision laid the groundwork for the complex common law of personal jurisdiction.

It has been substantially modified in subsequent decisions, especially International Shoe Co. v. Washington (1945), but some parts remain.

The case included a colorful cast of characters attempting to build lives on the Oregon frontier.

Neff sought a land grant under the Donation Law of Oregon, an act of the United States Congress enacted on September 27, 1850.

In an attempt to speed up the process and deal with the requisite paperwork, the illiterate Neff hired attorney John H.

So to recoup his fee, Mitchell instead sought action in rem (in property): the piece of land he had helped Neff obtain, worth an alleged $15,000 (about $440,000 in 2020, adjusted for inflation[5]).

Though Neff had been prosperous in California, the Oregon action was apparently important enough to move his entire family there for a year to get his land back.

Mitchell characteristically escaped further investigation by bribing the Attorney General at the time, George Henry Williams.

Deady's disgust at the entire affair was well chronicled in his diary, and his total lack of trust in Mitchell's character was reflected in his decision.

[1] Deady's narrow decision in favor of Neff is described by Dean Perdue as surprisingly modern, though quite conservative in its approach.

The Due Process Clause of the United States Constitution requires that defendants to a lawsuit be properly notified.

In an ideal world, every defendant would be personally handed the summons of a lawsuit, but the expense and inefficiency of this method results in other options for giving notice.

Mitchell had made the mistake of not attaching the parcel at the start of his action against Neff, instead waiting until after judgement had been rendered.

His chief concerns were that the decision would invite litigation, upend property law, and that it impinged on state sovereignty.

He held especial rage for Chief Justice John Marshall, whom he termed the head of a judicial oligarchy that had supplanted democracy.

[1] Neff had also defended the property in an 1875 action from Mary McGuire (also spelled Maguire), who had bought a portion of it from Pennoyer and sought to quiet title.

The 1885 election had an unusual connection to the case: the judge of the lower court, Matthew Deady, came into possession of Mitchell's love-letters from yet another affair.

Indeed, it seems the basis of a state's authority to decide the "status" of its citizens, for example, as in a divorce without having personal jurisdiction over the respondent remains undisturbed.

The doctrines governing personal jurisdiction in the United States have spawned a great deal of discourse within the Supreme Court of the United States with many cases finetuning and elaborating upon the concept, which has led to the test used today, in which the overall scope of the test for determining whether a court may exert personal jurisdiction over a party has been expanded in certain respects but narrowed in others.

Nevertheless, in every case, the Supreme Court has ruled that such analyses must comport with the Due Process Clause of the Fourteenth Amendment.

The 1945 case International Shoe Co. v. Washington mostly replaced the Pennoyer framework with the "minimum contacts" standard for personal jurisdiction.

While scholars disagree as to the extent that federal legal procedure remains bound to its direct legacy, Pennoyer is a seminal sample of early jurisdictional jurisprudence.