Abstract
Although the Supreme Court claims that its six personal jurisdictions in the last seven years have been unremarkable applications of existing law, the Court is dissembling. In fact, the Court has severely constricted plaintiff forum choice, often leaving U.S. plaintiffs injured in the U.S. with no U.S. forum, or no rational one. Although commentators refer to this sea change as a "stealth" revolution, in fact the vast change is the law is obvious to any commentator paying close attention. This article argues that a central difficulty is that the Supreme Court does not have any clear rationale for employing the Due Process Clause to closely regulate personal jurisdiction, leading to vacillating results and untenable decisions.