Personal jurisdiction proceedings formally focus on the defendant’s liberty interest in avoiding the reach of an overextending court. In this Note, R. D. Rees argues that such an approach may fail to provide the plaintiff due process. The laws of various jurisdictions convert a single set of underlying facts into distinct causes of action, and the Supreme Court understands these statutory programs to create property interests. Although a plaintiff may not have a substantive right to a cause of action in a given jurisdiction, she does have the procedural right to have her interests considered before dismissal for lack of jurisdiction finally destroys her property claim. Since the defendant-centered nature of the “minimum contacts” test does not appear to allow for such consideration, Rees proposes a modest adjustment to the current test that would weigh plaintiff interests among the totality of the circumstances.