The goal of the Seider cases, providing a resident plaintiff with a home forum, must be balanced with the desirability of forcing the insured and the insurer to defend in the plaintiff's home forum. The thesis presented is that a direct action against the insurer would achieve such balance.
Steven R. Hunsicker,
Jurisdiction--Quasi in Rem: Seider v. Roth to Turner v. Evers--Wrong Means to the Right End,
San Diego L. Rev.
Available at: https://digital.sandiego.edu/sdlr/vol11/iss2/11