Problem
Explain what is meant by the bolded piece below: "but now that the arrest of a civil defendant has given way to personal service of summons or other form of notice, due process requires...minimum contacts." How did the arrest of a civil defendant lead to that new requirement of minimum contacts?
"Historically, the jurisdiction of courts to render judgment in personam is grounded on their de facto power of the D's person. Hence, his presence within the territorial jurisdiction of a court was prerequisite to its rendition of a judgment personally binding him. (Pennoyer v. Neff). But now that the capias ad respondendum [the arrest of the civil defendant] has given way to personal service of summons or other form of notice, due process requires only that in order to subject a defendant to a judgment in personam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend "traditional notions of fair play and substantial justice." (Milliken v. Meyer)."