[1, 2] Quasi in rem jurisdiction "is best analyzed in terms of the two-pronged test this court has applied in the context of in personam jurisdiction." Camire v. Scieszka, 116 N.H. 281, 283, 358 A.2d 397, 399 (1976); see Pono v. Brock, 119 N.H. 814, 816, 408 A.2d 419, 420 (1979). First, the exercise of jurisdiction must be reasonable in light of New Hampshire's interest in the litigation.
In determining whether a court has quasi in rem jurisdiction, we consider "(1) whether the exercise of jurisdiction is reasonable in light of New Hampshire's interest in the litigation, and (2) whether the defendant has sufficient minimum contacts with New Hampshire so that, in the circumstances, the exercise of jurisdiction is consistent with the principles of fair play and substantial justice." Pono v. Brock, 119 N.H. 814, 816 (1979); see also Shaffer, 433 U.S. at 212 (holding that all assertions of state-court jurisdiction must meet the minimum contacts test set forth in International Shoe Co. v. State of Washington, 326 U.S. 310, 316 (1945)). CBI argues that FirstMerit has sufficient contacts with New Hampshire based upon: (1) FirstMerit's response to the demand for an account of its security interest; and (2) FirstMerit's disbursement of the fire insurance proceeds on EMC's behalf to pay CBI for repair of the grinder.
Hall v. Koch, 119 N.H. 639, 644, 406 A.2d 962, 965 (1979); Camire v. Scieszka, 116 N.H. 281, 283, 358 A.2d 397, 399 (1976); see also Shaffer v. Heitner, 433 U.S. 186 (1977). At the time it filed suit, the plaintiff obtained an attachment of the defendant's interest in the Sasseville estate in New Hampshire. Generally, attachment satisfies the statutory requirement for the exercise of quasi in rem jurisdiction and provides at least one contact between the defendant and the State. Pono v. Brock, 119 N.H. 814, 817, 408 A.2d 419, 421 (1979). However, there must also be sufficient contacts between the defendant and the forum State to satisfy the requirements of due process.