Chapman v. Deutsche Bank National Trust Co., 129 Nev. 314

Chapman plaintiffs owned property encumbered by a nonjudicial foreclosure; Deutsche Bank purchased at trustee's sale by credit bid.
Chapmans and Deutsche Bank initiated different actions: quiet title in district court and unlawful detainer in Reno justice court.
Chapmans alleged Deutsche Bank did not own the note or validly foreclose under NRS 107.080 and sought title relief.
Deutsche Bank removed the quiet title action to federal court and moved to dismiss; Chapmans sought remand to state court.
Ninth Circuit certified questions to Nevada Supreme Court about how Nevada law characterizes quiet title and unlawful detainer actions.
Nevada Supreme Court reframed the questions to whether the actions are in personam or in rem/quasi in rem and answered accordingly.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Quiet title under NRS 40.010 is in rem or in personam?	Chapman argues the action is in rem or quasi in rem.	Deutsche Bank contends it is in personam.	Quiet title is in rem or quasi in rem.
Unlawful detainer under NRS 40.255(1)(c) is in rem or in personam?	Chapman asserts it affects possession in rem/quasi in rem.	Bank argues in personam jurisdiction governs the action.	Unlawful detainer is in rem or quasi in rem.

Pennoyer v. Neff, 95 U.S. 714 (U.S. Supreme Court 1877) (fundamental in rem jurisdiction concept)
Shaffer v. Heitner, 433 U.S. 186 (U.S. Supreme Court 1977) (personal jurisdiction limitations; in rem/quasi in rem context)
Penn Gen. Cas. Co. v. Pennsylvania ex rel. Schnader, 294 U.S. 189 (U.S. Supreme Court 1935) (prior exclusive jurisdiction principle)
United States v. $79,123.49 in U.S. Cash & Currency, 830 F.2d 94 (7th Cir. 1987) (in rem vs in personam jurisdiction discussion)
Arndt v. Griggs, 134 U.S. 316 (U.S. Supreme Court 1890) (title interests and in rem concept)
Yori v. Phenix, 149 P. 180 (Nev. 1915) (title vs possession in adverse proceedings)