McGee v. International Life Insurance Co.

Citation. 355 U.S. 220 (1957)

Brief Fact Summary.

Plaintiff sued Defendant to enforce a life insurance policy.

Synopsis of Rule of Law.

Consistent with due process, a state court may render a binding judgment against a nonresident defendant who enters a contract with substantial connection to the state.

Facts.

Lowell Franklin, a resident of California, purchased an accidental death life insurance policy from International Life Insurance Co. (Defendant). The policy was accepted and certified through mail. After his death, Defendant refused to pay on the ground that Franklin had committed suicide. Lulu McGee (Plaintiff), Franklin’s mother and the beneficiary of his life insurance policy, brought suit in California against Defendant.

Issue.

Did the California court violate due process when it entered judgment against Defendant, a nonresident of the state?

Held.

No, California did not violate due process by rendering judgment against Defendant.

Discussion.

The Court determined that, under the precedent set by International Shoe v. Washington, the California court did not violate due process by entering a binding judgment against Defendant. The contract between Defendant and Franklin substantially connected Defendant to California because the contract was delivered in California, the insurance premiums were mailed from California, and Franklin was a resident of California when he died. The Court balanced California’s interest in providing a means of redress for its resident, the burden on the Plaintiff otherwise forced to litigate out of state, and the minimal burden on the Defendant in this case who had adequate notice and sufficient time to prepare for the lawsuit.