McGee v. International Life Ins. Co.

Brief Fact Summary.

Petitioner, a California resident, recovered a judgment against Respondent in California state court based on her status as beneficiary of her son’s life insurance policy. Respondent, whose principal place of business was Texas, had refused to pay on the policy, claiming that the son had committed suicide. Petitioner sought to enforce the judgment in Texas, but the Texas courts refused to give full faith and credit to the California judgment.

Synopsis of Rule of Law.

For due process purposes, it is sufficient for a state’s jurisdiction to be based on a contract which had a substantial connection with a state.

Facts.

Petitioner’s son purchased a life insurance policy from an Arizona company. Respondent subsequently assumed the Arizona company’s  insurance obligations. Respondent mailed a reinsurance certificate to the son, in California, offering to continue to insure him. The son accepted, and thereafter mailed premiums due under the policy to Respondent. After the son died, Petitioner, as the beneficiary under the policy, sought to recover the proceeds. Respondent refused to pay, claiming that the son had committed suicide. Petitioner recovered a judgment against Respondent in California state court. She sought to enforce the judgment in Texas, but the Texas courts refused to give full faith and credit to the California judgment. Respondent never had an office in California, nor did it solicit any business in California (with the exception of the son’s policy).

Issue.

Did the Texas court err in not according full faith and credit to the California state judgment?

Held.

Yes. It was sufficient for due process purposes that Petitioner’s lawsuit was based on a contract that had substantial connection with the state of California.

Discussion.

Due process was satisfied if the lawsuit was based on a contract that had substantial connection with the state. Here, the contract was delivered in California, the premiums were mailed to California and the insured was a resident of California when he died.