“Who among us has not relished the extraordinary gift the [U.S.] Supreme Court gave to civil procedure teachers in the form of J. McIntyre Machinery, Ltd. v. Nicastro, allowing professors to punctuate the already absurd personal jurisdiction case line with the story of the unlucky Mr. Nicastro (he who lost four fingers to a metal shearing machine in New Jersey), with nary a place to sue?” University of Texas at Austin School of Law Professor Linda Mullenix, opening her review of a recently released paper by Duke University School of Law Professor Stephen Sachs titled “How Congress Should Fix Personal Jurisdiction.” Sachs refers to this “near-perfect teaching vehicle” as “an incoherent three-way split.”

Jotwell: Courts Law, April 15, 2013.