95 U.S. 714 (1877).

An 1877 United States Supreme Court opinion in which the Court upheld the exercise of state court jurisdiction when a defendant was served with process within the state.

Facts: Neff (P) attached the validity of a sheriff’s sale of his property to satisfy a personal judgment obtained against him where service was by publication.

Rule: Where the object of an action is to determine the personal rights and obligations of the parties, service by publication against a nonresident is ineffective to confer jurisdiction upon the court.

Analysis: No state can exercise direct jurisdiction and authority over persons or property outside of its boundaries.  The state, however, may exercise jurisdiction over persons and property inside the state in ways that will affect persons and property outside the state.  In proceeding against a nonresident’s property, located within the forum state, substituted service of process is only effective in a proceeding in rem.

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