This articles analyzes the growth and development of the doctrine of personal jurisdiction and the Supreme Court's consideration and application of that doctrine in the recent case of Asahi Metal Industry Co. v. Superior Court. Asahi is significant both because of the nature of the suit and the nationality of the third-party defendant. The Supreme Court for the first time directly addressed the constitutionality of the ‘stream of commerce’ doctrine of personal jurisdiction, a jurisdictional theory that has been employed increasingly in recent years in products liability actions. Asahi also is one of the few cases in which the Court has considered the assertion of personal jurisdiction over a foreign country defendant.
R. Lawrence Dessem, Personal Jurisdiction After Asahi: The Other (International) Shoe Drops, 55 Tenn. L. Rev. 41 (1987)