Hanson v. Denckla

357 U.S. 235 (1958)

Yeazell, p. 117-118


Facts: A family fought over the estate of Mrs. Donner, who had established a trust in Delaware but had then moved to Florida and died there. If Florida had jurisdiction, one daughter would get everything, while if Delaware had jurisdiction, three daughters would share.


Issue: Are there sufficient contacts between the trust company and the state of Florida for the state to have specific jurisdiction?


Rule: If there are only minimal contacts between a state and a defendant, then the contacts must be closely related to the claim.


Analysis: The court says that the contacts were not sufficient in volume, nor were they sufficiently related.The court concedes that the trust paid income to her in Florida and she did a little bit of work on administering the trust from Florida, but the court says thatís not enough.


Conclusion: The court rules that Florida does not have specific jurisdiction over this matter.


Notes and Problems


1.     There is a difference between the two cases.

a.      It seems reasonable to me that if you purchase a company that does business with clients far away, you should expect to become involved in legal matters in those jurisdictions.

b.     The factual difference between the two cases is that the contact in McGee is completely related to the claim while the contacts in Hanson are not really that related.However, I think the real reason these cases came to different results is that the court in Hanson didnít want one daughter to have all the stuff.I think this may have tipped the scales against giving Florida jurisdiction.

2.     I was wondering about this in class: whether a foreign national or international corporation can sue or be sued in the U.S., and if so, in what court.


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