Marzano is overruled, and there was much rejoicing
By Michael G. Cortina
Commercial Banking, Collections, and Bankruptcy,
April 2014
This article briefly reviews the decision of BAC Home Loans Servicing, LP, f/k/a Countrywide Home Loans Servicing, LP v. Mitchell and how it overruled Marzano and held that a party’s waiver of personal jurisdiction is prospective only and does not retroactively validate void orders entered by the circuit court without personal jurisdiction.
Jurisdiction of Illinois courts based on Internet content without Zippo
By George S. Bellas & A. Patrick Andes
Civil Practice and Procedure,
July 2012
In recent years, courts have returned to a more traditional analysis to determine whether personal jurisdiction exists in Internet-related cases. The United States Supreme Court Calder v. Jones case in 1984 crafted the “effects” test, which would become the blueprint for contemporary Internet jurisdiction analysis in much of the United States and in Illinois, specifically.
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