therein by no agents whatsoever, a foreign mail order insurance company
had through its policies developed such contacts and ties with Virginia
residents that the State, by forwarding notice to the company by
registered mail only, could institute enforcement proceedings under its
Blue Sky Law leading to a decree ordering cessation of business pending
compliance with that act. The due process clause was declared not to
"forbid a State to protect its citizens from such injustice" of having
to file suits on their claims at a far distant home office of such
company, especially in view of the fact that such suits could be more
conveniently tried in Virginia where claims of loss could be
investigated.[723]

Service of Process

Actions in Rem--Proceedings Against Land.--For the purpose of
determining the extent of a nonresident's title to real estate within
its limits, a State may provide any reasonable means of imparting
notice.[724] Precluded from going beyond its boundaries and serving
nonresident owners personally, States in such cases of necessity have
had recourse to constructive notice or service by publications. This
they have been able to do because of their inherent authority over
titles to lands within their borders. Owners, nonresident as well as
resident, are charged with knowledge of laws affecting demands of the
State pertinent to property and of the manner in which such demands may
be enforced.[725] Accordingly, only so long as the property affected has
been brought under control of the Court, will a judgment obtained
thereto without personal notice to a nonresident defendant be effective.
Insofar as jurisdiction is thus required over a nonresident, it does not
extend beyond the property involved.[726] Consistently with such
principles, San Francisco, after the earthquake of 1906, had destroyed
nearly all records, permitted titles to be reestablished by parties in
possession by posting summons on the property, serving them on known
claimants, and publishing them against unknown claimants in newspapers
for two weeks.[727]

Actions in Rem--Attachment Proceedings.--In fulfillment of the
protection which a State owes to its citizens, it may exercise its
jurisdiction over real and personal property situated within its borders
belonging to a nonresident and permit an appropriation of the same in
attachment proceedings to satisfy a debt owed by the nonresident to one
of its citizens or to settle a claim for dama