Hanson v. Denckla

357 U.S. 235 (1958)

What's Going On?

The Supreme Court granted certiorari to decide whether Florida had jurisdiction over nonresident defendants in consolidated cases involving the disposition of assets in a trust.

Who's Who?

[Elizabeth Donner] Hanson  :

Executrix of Mrs. Donner's estate.

[Katherine R.] Denckla, et al :

Daughters of the deceased.

Wilmington Trust Company :

Delaware corporation and trustee of the assets at issue in this case. (The Wilmington Trust Company will be referred to as Defendant.)

Facts:

Mrs. Donner, a deceased mother established a trust in Delaware and subsequently moved to Florida, where she died. Following the death of the Mrs. Donner, her heirs fell into a dispute over the trust assets. The determinative factor in deciding which party would receive Mrs. Donner's estate was whether Florida or Delaware courts had jurisdiction over [the Wilmington Trust Company, a Delaware corporation and] trustee of the assets at issue in this case. [The parties (Hanson, Denckla) brought separate suits for declaratory judgments in an attempt to obtain the trust assets. The cases were decided inconsistently. The Supreme Court granted certiorari to hear the cases, which were consolidated.]

Issue:

May the unilateral activity of those who claim some relationship with a nonresident defendant provide the necessary minimum contacts required to establish personal jurisdiction over that defendant?

Decision:

No. The requirements for personal jurisdiction have lessened due to the progress in communications and transportation, which have made the defense of a suit in a distant forum less burdensome; however, these restrictions on the personal jurisdiction of state courts have not disappeared. The restrictions result from territorial limitations on state power, and minimum contacts between a defendant and a state are prerequisite to the state's exercise of power upon the defendant, despite the ease with which the defendant might have access to the distant forum. Those minimum contacts do not exist here because Defendant, [the Wilmington Trust Company], does not maintain an office, transact business, nor solicit business within Florida. The relationship of Florida to the action arose only after the establishment of the trust, when Mrs. Donner moved to Florida. Mrs. Donner's unilateral activity of moving to Florida is insufficient to satisfy the requirement of minimum contacts between Defendant and the state. In order to be subject to suit within a forum, a nonresident defendant must somehow purposefully avail itself of the privilege of conducting activities within the forum state, thereby invoking the benefits and protections of its laws.

Basic Rule:

In order to be subject to suit within a forum, a nonresident defendant must somehow purposefully avail itself of the privilege of conducting activities within the forum state, thereby invoking the benefits and protections of its laws.

Terms:

Executrix :

Feminine form of “executor” – a person appointed by one who died leaving a will to carry out the instructions contained in the will.

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