No coherent or cohesive procedure or theory has emerged either in regard to the entire question of personal jurisdiction in federal courts or in regard to federal question cases. The cases and courts are in disarray, both as to when a federal standard should apply to the question of amenability to service of process and as to what a federal standard might require. The purpose of this article is to examine the problem in the context of the various types of cases in which it might arise and to prescribe some consistent, sensible scheme of personal jurisdiction in federal question cases. This scheme would embody the basic principles of the federal judicial system while recognizing practical limitations where required.
Irene Deaville Sann, Personal Jurisdiction in Federal Question Suits: Toward a Unified and Rational Theory for Personal Jurisdiction over Non-Domiciliary and Alien Defendants, 16 Pac. L.J. 1 (1984), available at http://digitalcommons.pace.edu/lawfaculty/529/.