Does Burnham overturn Shaffer?

Personal jurisdiction is all about where you can sue, and where someone can sue you. It's about which courts can drag you thereto and declare binding judgements against you.

Would it be fair to defend yourself in the courts of a state in which you had no relation to the laws? No, of course not because you haven't availed yourself of their laws, so you're not liable under them. In this case, life is fair :)

Anyway, courts have jurisdiction over individuals and property that have "purposefully availed" themselves of laws within that state. No availment, no jurisdiction.

Unless of course you're Burnham and are served within the legal boundaries of that state, in which case the court has jurisdiction, and let's be honest, you're probably screwed.

Lesson: If you think someone in a state wants to summon you, stay the hell away.