Hanson v. Denckla

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Hanson v. Denckla
Seal of the United States Supreme Court.svg
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

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.

Contents

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

Related Research Articles

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Minimum contacts

Minimum contacts is a term used in the United States law of civil procedure to determine when it is appropriate for a court in one state to assert personal jurisdiction over a defendant from another state. The United States Supreme Court has decided a number of cases that have established and refined the principle that it is unfair for a court to assert jurisdiction over a party unless that party's contacts with the state in which that court sits are such that the party "could reasonably expect to be haled into court" in that state. This jurisdiction must "not offend traditional notions of fair play and substantial justice". A non-resident defendant may have minimum contacts with the forum state if they 1) have direct contact with the state; 2) have a contract with a resident of the state; 3) have placed their product into the stream of commerce such that it reaches the forum state; 4) seek to serve residents of the forum state; 5) have satisfied the Calder effects test; or 6) have a non-passive website viewed within the forum state.

Calder v. Jones, 465 U.S. 783 (1984), was a case in which the United States Supreme Court held that a court within a state could assert personal jurisdiction over the author and editor of a national magazine which published an allegedly libelous article about a resident of that state, and where the magazine had wide circulation in that state.

Carnival Cruise Lines, Inc. v. Shute, 499 U.S. 585 (1991), was a case in which the Supreme Court of the United States held that United States federal courts will enforce forum selection clauses so long as the clause is not unreasonably burdensome to the party seeking to escape it.

Burger King v. Rudzewicz, 471 U.S. 462 (1985), is a notable case in United States civil procedure that came before the Supreme Court of the United States addressing personal jurisdiction.

Florida v. Thomas, 532 U.S. 774 (2001), is a United States Supreme Court case decided in 2001. The case brought to the court concerned the extent of the Court's earlier decision in New York v. Belton, concerning whether a person was in custody, a determination central to allowing evidence seized in an automobile search to be presented in trial. However, the Court unanimously dismissed the case because the decision of the Florida state courts was not "final".

Bristol-Myers Squibb Co. v. Superior Court of California, San Francisco County, 582 U.S. ___ (2017), was a United States Supreme Court case in which the Court held that California courts lacked personal jurisdiction over the defendant on claims brought by plaintiffs who are not California residents and did not suffer their alleged injury in California. It is part of a group of six cases decided since 2011 that have greatly changed the application of personal jurisdiction. It was criticized by legal scholars for favoring corporations, and not solving the underlying vagaries of the law.

References

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