Keywords: trust, minimum contacts, law, personal jurisdiction, due process, res judicata, case briefs, beneficiary, in personam jurisdiction
Summary of Hanson v. Denckla, 357 U.S. 235, 78 S. Ct. 1228, 2 L. Ed. 2d 1283 (1958).
Mrs. Donner, a Pennsylvania resident, established a trust in Delaware naming a Delaware bank (“Denckla”, D) as trustee. Donner was the income beneficiary of the trust during her lifetime and the remainder was to go to her beneficiary. Donner moved to Florida and drafted a will naming her daughters (“Hanson”, P) as her primary heirs. Two grandchildren, the daughters of Donner’s third daughter, were named as the beneficiaries of the trust.
Donner died and Hanson brought suit in Florida seeking to have the balance of the trust fund placed into the estate for probate on the grounds that the appointment of Donner’s grandchildren as beneficiaries was invalid. While that suit was pending another suit was filed in Delaware to determine the status of the trust.
The Florida court found in favor of Hanson, holding that the trust was invalid and that the balance of the trust belonged to the estate. In the Delaware proceeding, Hanson asserted that the judgment in Florida was res judicata in regards to the Delaware action. The Delaware court held that the Florida court did not have in personam jurisdiction over defendant trustee and refused to honor the Florida court’s judgment. The Delaware court found that the trust was valid.
The U.S. Supreme Court granted certiorari to resolve the issue of whether Florida or Delaware had jurisdiction over the trust assets and whether the Florida court could acquire jurisdiction over the defendant.
- How extensive must a party’s contact with a state be for the courts of that state to be able to exercise jurisdiction over that party?
Holding and Rule (Warren)
- There be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.
A state cannot exercise jurisdiction over a nonresident defendant if that party has only sporadic and inadvertent contacts with the state. The court held that while International Shoe Co. v. Washington expanded the power of states to obtain personal jurisdiction over parties there were still limits to that power.
Nonresidents must be protected from the burden of defending a suit in a distant and inconvenient court. In this case the defendant bank had no office and transacted no business in Florida. The court held that this cause of action did not arise from acts or transactions in Florida. There must be some act by which the defendant purposely avails itself of the privilege of conducting activities within the forum State. There was no such act here.
Judgment of the Delaware court affirmed.
Florida is the most convenient forum. Donner lived in Florida, her heirs lived there, she died there, and her administrators lived there. The defendant purposefully chose to carry on business with a Florida resident. There are sufficient contacts with Florida to justify jurisdiction over the defendant and it was not unfair to subject the bank to suit there. Florida has a strong interest in this litigation.
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