Hanson v. Denckla

Hanson v. Denckla, 357 U.S. 235 (1958), was a case decided by the Supreme Court of the United States regarding personal jurisdiction in the context of assets held in trust.

Hanson v. Denckla
Argued March 10, 1958
Decided June 23, 1958
Full case nameElizabeth Donner Hanson v. Katherine N.R. Denckla
Citations357 U.S. 235 (more)
78 S. Ct. 1228; 2 L. Ed. 2d 1283
Holding
The unilateral activity of a single person who has some relation to a nonresident defendant does not fulfill the minimum contacts test to establish personal jurisdiction
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black · Felix Frankfurter
William O. Douglas · Harold H. Burton
Tom C. Clark · John M. Harlan II
William J. Brennan Jr. · Charles E. Whittaker
Case opinions
MajorityWarren, joined by Harlan, Frankfurter, Clark, Whittaker
DissentDouglas
DissentBlack, joined by Burton, Brennan
Laws applied
U.S. Const. amend. XIV

Factual background

A family trust was created by Mrs. Donner, who lived in Pennsylvania. The trust was incorporated in Delaware, and a Delaware bank was the trustee. Donner later changed her state of domicile upon moving to Florida where she eventually died. The will was admitted to probate in Florida, and the court addressed the question of whether the Florida court or the Delaware trustee had jurisdiction over the trust.

Decision

The Court decided that the Florida court lacked jurisdiction based on the minimum contacts test that had developed over the course of several decades of Supreme Court Jurisprudence. The trust company had no substantial business with Florida and no offices in Florida. The only contact with Florida was the fact that Donner moved there, which was ruled insufficient to support jurisdiction.[1]

See also

References
  1. Yeazell, C. Civil Procedure, Seventh Edition. Aspen Publishers, New York, NY: 2008.
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