2. How did Justice Scalia interpret the word “traditional” in the passage “traditional notions of fair play and substantial justice”? Are other definitions plausible? See Greenberger, Justice Scalia’s Due Process Traditionalism Applied to Territorial Jurisdiction:

The Illusion of Adjudication Without Judgment, 33 B.C. L. Rev. 981 (1992). Is the debate in Burnham evidence of a deeper disagreement between Justice Scalia and Justice Brennan about the Due Process Clause and its relation to state power? Have the Court’s later decisions about personal jurisdiction resolved these differences?