McGee v. International Life Insurance Co.
Citation
355 U.S. 220 (1957)
Facts
International Life Insurance Co. was a Texas corporation. It issued a life insurance contract — a reinsurance assumption — to Lowell Franklin, a California resident, and mailed him a certificate from Texas. Franklin paid premiums from California by mail. After Franklin died, his mother (the beneficiary) tried to collect; the Texas company refused to pay. She obtained a California judgment, which Texas refused to enforce. International Life had no other contacts with California.
Issue
Did California have specific personal jurisdiction over a Texas insurance company that had issued a single insurance contract to a California resident and received premium payments from California?
Holding
Yes. The Supreme Court held that California had jurisdiction. The insurer had a single contract directed into California; the cause of action arose directly from that contract; and California had a strong interest in protecting its residents from out-of-state insurers.
Rule / Doctrine
Specific jurisdiction from a single contact: even a single purposeful contact with the forum state can support specific jurisdiction when the plaintiff’s cause of action arises directly from that contact. The “nationalization of commerce” rationale makes it constitutionally reasonable to require a defendant to defend where they directed their business activity.
Significance
McGee marked a high-water point for expansive specific jurisdiction and is the key counterpoint to Hanson v. Denckla (decided the same year). McGee = insurer reached into California; Hanson = trustee never reached into Florida. Together they define the outer contours of purposeful availment: the defendant must affirmatively direct activity into the forum.