The Supreme Court established the basic rules covering people who were not citizens or residents of states.
To secure judgment in a contract suit, a plaintiff in Oregon attached the real property of a noncitizen, nonresident of Oregon by constructive service through a legal notice in a local newspaper. By an 8-1 vote, the Supreme Court ruled against the plaintiff, holding that these steps were insufficent to secure jurisdiction over the defendant. The Court ruled that a state had jurisdiction over those within its borders and none over those outside its borders. This simple distinction became unworkable in the twentieth century because of modern transportation and communications and its failure to provide a basis for jurisdiction over corporations. International Shoe Co. v. Washington
States’ rights and state sovereignty