What is the test for determining whether a federal or state court has jurisdiction to hear a motion in the case of Cannon v. C. Cannon?

3 In setting forth the issue there presented for decision, the court stated: 'The obstacle insisted upon is that the (lower) court lacked jurisdiction because the defendant (parent) a foreign corporation, was not within the state. No question of the constitutional powers of the state, or of the federal government, is directly presented.' (267 U.S. at 336, 45 S.Ct. at page 251, emphasis added.) The issue in the Cannon case then, would appear to have turned upon application of the traditional doctrines governing assertion of jurisdiction, as set forth in such cases as Pennoyer v. Neff, 95 U.S. 714, 722, 24 L.Ed. 565.