1L Law Source

Heading: Hanson v. Denckla, 357 U.S. 235 (1958).

Facts: - Dora Donner set up a trust in Delaware which named a Delaware Bank as trustee.

She reserved the power (of appointment) to designate to whom the trust would pass on to.
Donner later moved to Florida.
She executed the power of appointment from Florida and named Hanson as the heir to the trust.
At the same time she named Denckla as the heir to a will passing on the residue of her property.
Denckla group sought to invalidate the trust so that trust assests would pass on to him.
Hanson sought to uphold the trust.
Two suits were filed. Florida held for Denckla. Delaware refused to give full faith and credit to the Florida judgement and held for Hanson.

Procedure: Denckla group sought to invalidate a trust, Hensen group sought to uphold the trust. Two suits were filed: one in Florida and one in Delaware. Each came to conflicting decisions. The Supreme Court granted cert to resolve the underlying jurisdictional questions.

Issue: Was Florida justified in exercising jurisdiction over the Delaware trustee?

Rule: The International Shoe test was not satisfied because the absent trustee did not have the necessary minimum contacts.

Holding: The SC upheld the judgement of the Delaware court and held that the Florida courts had no jurisdiction over the Delaware trustee.

Rationale: In rem jurisdiction was rejected. The court felt in personam jurisdiction was slightly stronger, but not enough as there were not the requisite kind of contacts needed. Delaware trustee never solicited business in Florida or engaged in purposeful activity in Florida. This is why it is different from previous cases. The court said that regarding the expansion of jurisdiction "it is a mistake to assume that this trend heralds the eventual demise of all restrictions on the personal jurisdiction of state courts.

Policy/Notes: Justice Black dissent: There is nothing in the Due Process clause that denied Florida jurisdiction. Florida was a reasonable jurisdiction for all. There was nothing fundamentally unfair in subjecting the corporate trustee to the jurisdiction of the Florida courts.

California solved jurisdiction problems by leaving the law wide open: "A court of this state may exercise jurisdiction on any basis not inconsistent with the Constitution of this state or of the United States.