Hanson v. Denckla

Citation. 357 U.S. 235 (1958)

Brief Fact Summary.

Plaintiffs sued to stop Defendants from obtaining money appointed to them in their grandmother’s will.

Synopsis of Rule of Law.

A defendant must purposefully avail itself of the privilege of conducting activities within the forum state, invoking the benefits and protections of its laws, to constitute sufficient minimum contacts for the forum state to establish personal jurisdiction over the defendant.

Facts.

Dora Browning Donner, a Pennsylvania resident, established a trust in Delaware with a Delaware bank as trustee. Subsequently, Donner moved to Florida where she executed a will before her death providing two daughters (Plaintiffs) with $500,000 each and $200,000 apiece to two of her grandchildren (Defendants). Plaintiffs sued Defendants in Florida, arguing that the money appointed to the Defendants was invalid.

Issue.

Did the Florida court have personal jurisdiction over the trustee, sufficient to enter judgment regarding the distribution of the trust?

Held.

No, the Florida court did not have personal jurisdiction over the trustee in Delaware. The Florida court’s judgment is reversed and the Delaware court’s judgment is affirmed.

Discussion.

Under the law established in International Shoe, the Court determined that the trustee did not have sufficient minimum contacts with Florida. The company did not have an office in Florida, did no business in Florida, did not attempt to solicit business in Florida, and the trust agreement entered between the company and Donner did not occur in Florida. Thus, the trustee did not purposefully avail itself of the privilege of conducting activities within Florida sufficient to exercise personal jurisdiction over the trustee.