Hanson v. Denckla Case Brief

Why is the case important?

“Plaintiff Donner had established a trust in Delaware and later moved to Florida where she died. Following her death, a family fight arose over whether Florida or Delaware courts had jurisdiction over the trust assets.
Synopsis of Rule of Law. The unilateral activity of a Plaintiff who claims some relationship with a non-resident Defendant cannot satisfy the requirement of contact with the forum state.”

Facts of the case

Question

Whether a non-resident 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.

Answer

No. The Supreme Court of the United States said that Florida had no jurisdiction. The unilateral activity of a Plaintiff who claims some relationship with a non-resident defendant cannot satisfy the requirement of contact with the forum state.

Conclusion

Florida courts lacked jurisdiction in rem over the action involving the trust, since the trust situs was in another state, and that those courts also lacked jurisdiction in personam over the trustee  because there were no minimum contacts with Florida prerequisite to the exercise of power over him. And, since it was found that under Florida law a trustee is an indispensable party over whom the Florida court must acquire jurisdiction before it has power to enter judgment in a proceeding affecting the validity of the trust, the Florida decree was held of no effect, and not entitled to full faith and credit in Delaware.

  • Case Brief: 1958
  • Petitioner: Hanson
  • Respondent: Denckla
  • Decided by: Warren Court

Citation: 357 US 235 (1958)
Argued: Mar 10 – 11, 1958
Decided: Jun 23, 1958