Hanson v. Denckla (a.k.a. Mrs. D's fighting daughters)

Hanson v. Denckla
357 U.S. 235 (1958)

Chief Justice Warren delivered opinion

Facts:

• Case arose from family fight over trust established by Mrs. Donner
• funded primarily from publicly traded stocks
• Mrs. D lived in PA but trust was created in Delaware w/ Del. bank and trustee
• Mrs. D moves to FL and later dies
• Will probated in FL
• Three daughters involved in fight
• if settled in FL, two daughters get everything to exclusion of third
• if not, all three daughters share inheritance

Issue:
Can Florida acquire jurisdiction over Delaware trustee?

Holding: No.

Reasoning:
Requirements for pers. juris. expanded since Pennoyer v. Neff but this doesn't mean because rule is more flexible that minimum contacts test isn't still valid for determining jurisdiction

Court says:

• Fail to find such contacts here
• def. (trustee) has no office in FL
• conducts no bus. in FL
• doesn't solicit bus. from FL by mail or in person
• coa did not arise out of any bus. done by trustee in FL
• FL's contact was when Mrs. Donner moved there and trust followed her
• Mrs. D conducted some trust administrative bus. but no record of trustee performing acts in FL
• Unilateral activity of Mrs. D w/ nonresident def. (Del. trustee) doesn't satisfy min. con. rqrmnts
• essential that def. purposefully avails him/self of privilege of conducting activities w/ forum state (thereby getting protections and benefits from state)
• Unilateral activity of Mrs. D w/ nonresident def. (Del. trustee) doesn't satisfy min. con.

Judgment: Affirmed

Opinions:
Justices Black, Burton, Brennan, and Douglas dissented

Thoughts:
When arguing over jurisdiction, the substantive law of one state may be better for you than another.