hanson v. denckla

2
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. Domer’s 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.

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Personal JurisdictionHanson v. Denckla357 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.