HANSON v. DENCKLA

Procedural Basis: Appeal from conflicting judgments in two separate but related actions for final disposition of a trust.

Facts: Dora Donner, a Pennsylvania resident, established a trust with a Delaware bank as trustee.  Donner was to collect the income from the trust during her lifetime and after her death the money would go to her beneficiary.  She retained the right to change her beneficiary at any time.  Donner drew up a will naming two of her daughters as her primary heirs.  She named two of her grandchildren, the children of her third daughter, as the beneficiaries of her trust.  When Donner died, the two daughters in her will brought suit in Florida against the trust company (?) claiming that the trust money should go to the Estate.  While this suit was pending, another action was filed in Delaware to determine the distribution of the trust money.  The Florida court determined that the trust was invalid and the money should go to the Estate.  The sisters tried to introduce this judgment in Delaware as res judicata.  The Delaware court held that the Florida court had not had jurisdiction over the trust company so it refused to recognize the validity of the action.  The Delaware court resolved that the trust had been valid and that the grandchildren should get the money.  Everybody appealed something and the U.S. Supreme Court consolidated both actions for review.

Issue: May a state exercise jurisdiction over a non-resident ? with only a sporadic and inadvertent contacts with the state, when those contacts do not give rise to the claim for which jurisdiction is being sought?

Rule: A state may not exercise jurisdiction over a ? if the ?’s contacts with the state are negligible and non-deliberate and the claim does not arise from those contacts.

Application: The trustee has no office in Florida, conducts no business there and does not advertise in Florida.  There must be some act by which the ? purposely avails himself of the privileges of conducting activities within the forum state.

Conclusion: Judgment of the Delaware courts is affirmed.  Judgment of Florida courts is reversed.

Dissent: (Black) The trust company (?) had sufficient contacts with Florida to justify Florida’s exertion of jurisdiction over it and there was nothing unfair about subjecting it to suit there.  Florida’s exercise of jurisdiction should have been upheld.