With the adoption of the Federal Rules of Civil Procedure in 1938, Congress finally attempted to provide a uniform standard for exercising personal jurisdiction in federal courts. Despite that attempt, there is currently no uniform method for acquiring personal jurisdiction in federal question cases. A contributing factor to the lack of uniformity is Federal Rule of Civil Procedure 4. This article calls for a uniform personal jurisdiction standard in federal question cases. In so doing, it examines the three ways to acquire personal jurisdiction under Rule 4 and evaluates the adequacy of each method. Because some federal courts rely on the personal jurisdiction analysis developed for state courts, this article explores the recent United States Supreme Court cases in that area. Finally, it explains the principles of due process developed by federal courts and examines their applicability to the exercise of jurisdiction in federal question cases.
Acquiring In Personam Jurisdiction in Federal Question Cases: Procedural Frustration Under Federal Rule of Civil Procedure 4, 1982 UTAH L. REV. 285