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Hanson v. Denckla

From lawbrain.com

Hanson v. Denckla, 357 U.S. 235 (1958) is a civil procedure case which held a party must have minimum contacts with a state that are purposeful and deliberate in order for the courts of that state to exercise jurisdiction over that party.

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Contents

Summary of Case Facts

Mrs. Donner, a Pennsylvania resident, established a trust in Delaware naming a Delaware bank (Denckla) as trustee. Donner, the income beneficiary of the trust during her lifetime, designated that the remainder go to her beneficiary. Donner moved to Florida and drafted a will naming her daughter (Hanson) as her primary heir. Donner died and Hanson brought suit in Florida seeking to have the balance of the trust fund placed into the estate for probate on the grounds that the appointment of Donner’s grandchildren as beneficiaries was invalid. While that suit was pending another suit was filed in Delaware to determine the status of the trust. The Florida court found in favor of Hanson, holding that the trust was invalid and that the balance of the trust belonged to the estate. In the Delaware proceeding, Hanson asserted that the judgment in Florida was res judicata in regards to the Delaware action. The Delaware court held that the Florida court did not have jurisdiction over defendant trustee and refused to honor the Florida court’s judgment. The Delaware court found that the trust was valid.

Issue

Whether Florida could acquire jurisdiction over the Delaware trustee and thereby award the estate to Mrs. Donner’s daughter.

Holding and Law

No. A defendant may not be called upon to defend an action in a different State unless “minimal contacts,” with that State are established. Defendant (Denckla) had no office and transacted no business in Florida. There must be some act by which the defendant purposely avails itself of the privilege of conducting activities within the forum State. There was no such act here.

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