Hanson v Denckla
357 U S 235 [1958]
Author:- Sam Biers

Relevant Facts: A family fight over the assets of Mrs. Donner, a deceased mother who had established a trust in DE and some yrs later moved to Fl, where she died.  When Mrs. Donner moved to FL she received her trust income from the trustee and she carried on several bits of trust administration while living in FL.  Mrs. Donner has three daughters who survive her.

Legal Issue(s): Whether FL could acquire jurisdiction over the DE trustee and thereby award the estate to Mrs. Donner’s daughter?

Court’s Holding: No, Fl does not have jurisdiction

Procedure: Fl ct ruled that it jurisdiction over the trust; S. Ct. Reversed.

Law or Rule(s): A df may not be called upon to defend an action in a foreign tribunal unless he has had the “minimal contacts,” with that State that are a prerequisite to its exercise of power over him.

Court Rationale: We fail to find that the defendant has the “minimal contacts,” in the circumstances of this case.  The defendant trust company has no office in FL, and transacts no business there . . . The record discloses no solicitation of business in that State either in person or by mail.  The trustee remitted the trust income to Mrs. Donner when she resided in FL, but the record discloses no instance in which the trustee performed any acts in FL. 

(Rule out of this Case) The unilateral activity of those who claim some relationship with a nonresident cannot satisfy the requirement of contact with the forum State.  The must be some act by which the df purposefully avails itself of the privilege of conducting activities w/i the forum State, thus invoking the benefits and protections of its laws.

Plaintiff’s Argument: The trustee carried out the business of the trust with Mrs. Donner while she resided in Fl, and therefor satisfied the minimal contacts with the forum State.

Defendant’s Argument: Neither the trust nor the trustee were ever located in Fl, nor was the trust company’s business carried out in FL.  Mrs. Donner’s trust business cannot satisfy the minimal contact requirement for the trust company.