Hanson v. Denckla
Citation
357 U.S. 235 (1958)
Facts
A Pennsylvania settlor established a trust with a Delaware trustee. She later moved to Florida, where she died. Florida courts purported to exercise jurisdiction over the trust assets held by the Delaware trustee in order to resolve a dispute over the estate. The Delaware trustee had no contacts with Florida — it never solicited business there, maintained no office there, and was incorporated in Delaware. The settlor’s move to Florida was entirely unilateral.
Issue
Did Florida have personal or in rem jurisdiction over the Delaware trustee and the trust assets it held, based solely on the fact that the settlor had moved to Florida?
Holding
No. The Supreme Court held that Florida lacked both in personam and in rem jurisdiction over the Delaware trustee and the trust assets. The trustee had no contacts with Florida, and the settlor’s unilateral decision to move there could not create jurisdiction over a third party who never directed any activities toward Florida.
Rule / Doctrine
Purposeful availment: for a state to exercise jurisdiction, there must be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum state, thereby invoking the benefits and protections of its laws. A plaintiff’s unilateral act of moving to a forum cannot establish the defendant’s minimum contacts there.
Significance
Hanson established the purposeful availment requirement as a limit on personal jurisdiction, directly complementing International Shoe. It distinguished McGee v. International Life Insurance Co. — in McGee, the insurer affirmatively reached into California; here, the trustee never reached into Florida. Hanson remains foundational for cases where plaintiffs or their property migrate to a forum but the defendant had no connection to it.