See Hutto v. Plagens, 254 Ga. 512, 513, 330 S.E.2d 341, 342 (1985); Oxmans' Erwin Meat Co. v. Blacketer, 86 Wis.2d 683, 273 N.W.2d 285 (1979); Lockert v. Breedlove, 321 N.C. 66, 361 S.E.2d 581 (1987); Nutri-West v. Gibson, 764 P.2d 693 (Wyo. 1988); Klavan v. Klavan, 405 Mass. 1105, 1106, 544 N.E.2d 863, 864 (1989); Nielsen v. Braland, 264 Minn. 481, 483, 484, 119 N.W.2d 737, 738 (1963); Read v. Sonat Offshore Drilling, Inc., 515 So.2d 1229, 1230 (Miss. 1987); Cariaga v. Eighth Judicial District Court, 104 Nev. 544, 762 P.2d 886 (1988); El-Maksoud v. El-Maksoud, 237 N.J. Super. 483, 486-490, 568 A.2d 140, 142-144 (1989); Carr v. Carr, 180 W. Va. 12 -14, 375 S.E.2d 190, 192 (1988); O'Brien v. Eubanks, 701 P.2d 614, 616 (Colo.App. 1985); Wolfson v. Wolfson, 455 So.2d 577, 578 (Fla.App. 1984); In re Marriage of Pridemore, 146 Ill. App.3d 990, 991-992, 497 N.E.2d 818, 819-820 (1986); Swarts v. Dean, 13 Kan. App. 2d 228, 766 P.2d 1291, 1292 (1989). C

       Several state courts have reached the same conclusion. In In re Marriage of Pridemore, 146 Ill.App.3d 990, 100 Ill.Dec. 640, 497 N.E.2d 818 (1986), the petitioner filed a petition in Illinois to modify a Tennessee divorce decree to increase child support payments. The nonresident respondent was personally served while in Illinois attending his parents' wedding anniversary.

Cf. Glen, An Analysis of "Mere Presence" and Other Traditional Bases of Jurisdiction, 45 Brooklyn L.Rev. 607 (1979). See Driver v. Helms, 577 F.2d 147 (1st Cir. 1978); Donald Manter Co., Inc. v. Davis, 543 F.2d 419 (1st Cir. 1976); Aluminal Industries, Inc. v. Newtown Commercial Associates, 89 F.R.D. 326 (S.D.N.Y. 1980); O'Brien v. Eubanks, Colo. App., 701 P.2d 614 (1984); Oxmans' Erwin Meat Co. v. Blacketer, 86 Wis.2d 683, 273 N.W.2d 285 (1979); Lockert v. Breedlove, 321 N.C. 66, 361 S.E.2d 581 (1987); Opert v. Schmid, 535 F. Supp. 591 (S.D.N.Y. 1982); In re Marriage of Pridemore, 146 Ill. App.3d 990, 100 Ill.Dec. 640, 497 N.E.2d 818 (1986); Humphrey v. Langford, 246 Ga. 732, 273 S.E.2d 22 (1980); Amusement Equipment, Inc. v. Mordelt, 779 F.2d 264 (5th Cir. 1985). "[A]ll assertions of state-court jurisdiction must be evaluated according to the standards set forth in International Shoe [ 326 U.S. 310, 66 S.Ct. 154, 90 L.Ed. 95, 161 A.L.R. 1057 (1945)] and its progeny."

In reaching this conclusion, we note that other courts addressing similar fact situations have concluded that personal jurisdiction may be exercised over a non-resident defendant if the defendant is served with process while he is physically present in the forum state. See Amusement Equipment, Inc. v. Mordeldt, 779 F.2d 264 (5th Cir. 1985); Opert v. Schmid, 535 F. Supp. 591 (S.D.N.Y. 1982); Aluminal Industries v. Newtown Commercial Assoc., 89 F.R.D. 326 (S.D.N.Y. 1980); Hutto v. Plagens, 330 S.E.2d 341 (Ga. 1985); Humphrey v. Langford, 273 S.E.2d 22 (Ga. 1980); In re Marriage of Pridemore, 497 N.E.2d 818 (Ill.App.Ct. 1986); Lockert v. Breedlove, 361 S.E.2d 581 (N.C. 1987). Additionally, we note that any hardships arising out of the exercise of personal jurisdiction over a non-resident defendant who is served within the forum can be avoided through recourse to the doctrine of forum non conveniens.

We hold that the minimum contacts test is inapplicable to cases in which the defendant is personally served within the forum state. See, e.g., Amusement Equipment, Inc. v. Mordelt, 779 F.2d 264 (5th Cir. 1985); Opert v. Schmid, 535 F. Supp. 591 (S.D.N.Y. 1982); Aluminal Indus., Inc. v. Newtown Commercial Assoc., 89 F.R.D. 326 (S.D.N.Y. 1980); Hutto v. Plagens 254 Ga. 512, 330 S.E.2d 341 (1985); Humphrey v. Langford, 246 Ga. 732, 273 S.E.2d 22 (1980); In re Marriage of Pridemore, 146 Ill. App.3d 990, 497 N.E.2d 818 (1986). In Pennoyer v. Neff, 95 U.S. (5 Otto) 714, 24 L.Ed. 565 (1878), the Supreme Court recognized that eminent jurists long had agreed that personal jurisdiction could be acquired solely by service of process on the defendant in the forum state.

However, a party may not be induced by artifice, trick, or fraud to enter the state for the sole purpose of being served with process. See In re Marriage of Pridemore, 146 Ill. App. 3d 990, 993, 497 N.E.2d 818, 820 (1986). Although the trial court entertained an oral motion to dismiss based on a lack of personal jurisdiction, the trial court limited respondent's ability to fully present her claim by denying her counsel's request for a two-day continuance to prepare and obtain affidavits.

In addition, the circuit court acquired in personam jurisdiction over respondent because he was personally served in Illinois according to the required statutory procedure. In re Marriage of Pridemore (1986), 146 Ill. App.3d 990, 497 N.E.2d 818. Having subject matter jurisdiction as to all issues before it and personal jurisdiction over respondent, the next appropriate issue confronting the circuit court was the effect of the Italian court decree, which consisted of a separation agreement providing for custody, child support and maintenance.

( In re Marriage of Hostetler (1984), 124 Ill. App.3d 31, 34, 463 N.E.2d 955; In re Marriage of Schuham (1983), 120 Ill. App.3d 339, 343, 458 N.E.2d 559; see also Galvin v. Galvin (1978), 72 Ill.2d 113, 119, 378 N.E.2d 510.) "[S]ervice of process on a nonresident person who is physically present in the State, albeit briefly, is a sufficient basis for in personam jurisdiction." ( In re Marriage of Pridemore (1986), 146 Ill. App.3d 990, 992, 497 N.E.2d 818, 820; see also In re Marriage of Hostetler (1984), 124 Ill. App.3d 31, 33, 463 N.E.2d 955.) Moreover, it is well established that a stipulation constitutes a general appearance ( People v. Estep (1955), 6 Ill.2d 127, 128, 126 N.E.2d 637; Tagert v. Fletcher (1908), 232 Ill. 197, 198-99, 83 N.E. 805; cf. Mauro v. Peterson (1984), 122 Ill. App.3d 466, 468, 461 N.E.2d 564) and, in particular, that a stipulation to a trial reconciliation between a separated couple is a general appearance ( McKnelly v. McKnelly (1976), 38 Ill. App.3d 637, 639, 348 N.E.2d 500, appeal denied (1976), 63 Ill.2d 557).

These courts have reaffirmed the long standing transient jurisdiction rule. See In re Marriage of Pridemore, 146 Ill.App.3d 990, 100 Ill.Dec. 640, 497 N.E.2d 818 (App.Ct. 1986) (Tennessee resident served while in Illinois to celebrate parents' wedding anniversary); Hutto v. Plagens, 254 Ga. 512, 330 S.E.2d 341 (Sup.Ct. 1985) (South Carolina resident served while visiting children in Georgia); Nutri-West v. Gibson, 764 P.2d 693 (Sup.Ct.Wyo. 1988) (California resident served while in Wyoming to attend convention); Jenkins v. Jenkins, 89 N.C. App. 705, 367 S.E.2d 4 (Ct.App. 1988) (Georgia resident served while in North Carolina for a brief visit in connection with employment); Cariaga v. Eighth Judicial District Court, 104 Nev. 82, 762 P.2d 886 (Sup.Ct. 1988) (California resident served while in Nevada to visit friends); Oxman's Erwin Meat Co. v. Blacketer, 86 Wis.2d 683, 273 N.W.2d 285 (Sup.Ct. 1979) (officer of Oklahoma corporation served while in Wisconsin); Lockert v. Breedlove, 321 N.C. 66, 361 S.E.2d 581 (1987) (non-resident served with process while in North Carolina to attend to business); Swarts v. Dean, 13 Kan. App. 2d 228, 766 P.2d 1291 (App.Ct. 1989