The case set forth a framework for evaluating when a defendant will be deemed to have minimum contacts with the forum state sufficient for the exercise of jurisdiction to be consistent with due process under the Fourteenth Amendment.
They contended that the ex parte sequestration procedure did not accord them due process of law as required by the Fourteenth Amendment, as construed by Supreme Court cases defining the requirements of personal jurisdiction, and that exercising quasi in rem jurisdiction over property in the forum state that was unrelated to the subject-matter of the litigation was constitutionally impermissible.
The primary purpose of 'sequestration' is not to secure possession of property pending a trial between resident debtors and creditors on the issue of who has the right to retain it.
Heitner argued that Delaware's interest in controlling the behavior of its corporations justified its assertion of personal jurisdiction over the defendants.
[4] Justice William J. Brennan, Jr. wrote a dissenting opinion, largely concurring in the Court's method of analyzing the jurisdictional issue, but disagreeing with the ultimate result.
Brennan agreed that International Shoe required a determination whether the defendants had at least minimum contacts sufficient to subject them to jurisdiction in Delaware.