October 17, 2017
In the past few years, the U.S. Supreme Court has been remaking the landscape of personal jurisdiction, generally imposing more exacting standards for the assertion of both general and specific jurisdiction. In this article, we discuss the recent decision in Australia and New Zealand Banking Group v. APR Energy Holding, which examines the question of what jurisdictional contacts are necessary to obtain discovery from a nonparty through a subpoena served pursuant to 28 U.S.C. § 1782.