So, what's been happening here since last I showed my face? I can tell you, I've been reading cases. Lots and lots of cases ...
It hinges on whether or not constructive notice is sufficient in an action in which the state only holds in rem jurisdiction, to attach.
Really. That's what I meant to say. :P
Shaffer v. Heitner and International Shoe Co. v. Washington add light to this issue.