Personal Jurisdiction

Hanson v. Denckla
357 U.S. 235 (1958)
Procedure:
The Florida court ruled that the state of Florida did have jurisdiction over the trust
in Delaware. The Delaware court ruled in favor of the plaintiff. The Florida
Supreme Court ruled in favor of the defendant. And the US Supreme Court ruled
in favor of the plaintiff.
Facts:
This case arose from a family dispute over a trust established by Domer. At the
time the trust was created, Domer lived in Pennsylvania, but the trust was
created in Delaware, with a Delaware bank as trustee. After creating the trust
Domer moved to Florida, where she eventually died. Domers will was probated in
Florida.
Issue:
Is a nonresident corporation with no offices nor any business transactions in a
state is subject to jurisdiction in the state by virtue of a unilateral activity of a
plaintiff having some relationship with the Defendant?
Law:
No matter how minimal the burden of defending in a foreign tribunal, a defendant
may not be called upon to do so unless he has had the minimal contacts with that
state that are a prerequisite to its exercise of power over him.
The unilateral activity of those who claim a relationship with the nonresident
defendant (the Delaware trustee) cannot satisfy the requirement of contact with
the forum state. It is essential in each case that 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
Reasoning:
The defendant trust company had no office in Florida, and does not transact any
business in that state either in person or by mail. The first relationship Florida had
to the agreement was when Domer became domiciled within the state, years
after the trust was created. Even though Domer carried on several bits of trust
administration within the state of Florida, the trustee never performed any acts
within the sate of Florida.
Holding:
Reversed.