Pennoyer v. Neff

Mitchell sued Neff for legal fees that Neff allegedly owed to him. The action was brought in Oregon, where Neff owned real property but was not a resident. After Neff was served by publication notice, he failed to respond, and Mitchell ultimately received a default judgment. Neff's land was sold at a sheriff's sale to satisfy the judgment, and Pennoyer bought it. Neff later sued in Oregon court to recover the property, once he found out about the sale, and he argued that the sale was improper because the court that issued the judgment against him did not have personal jurisdiction over him. This would have prevented it from adjudicating the personal rights between the two parties.