326 U.S. 310 (1945), expanded states' powers to claim jurisdiction over out-of-state parties. Prior to the ruling, states often could not establish jurisdiction (in personam jurisdiction) over outside parties, even when such parties could be shown to have contracted with or tortiously injured a state or its citizens. The Supreme Court held that when such “minimum contacts” are maintained with a state, notions of fair play and substantial justice require that the contacting party be made subject to that state's laws. Following the decision many states enacted “long-arm” statutes that extended their power to apply in personam jurisdiction. In Shaffer v. Heitner, 433 U.S. 186 (1977), the Court applied the same “minimum contacts” standard to cases involving questions of in rem (property) and quasi in rem (intangible property) jurisdiction.