Hanson v. Denckla
Encyclopedia
Hanson v. Denckla, 357 U.S. 235 (1958), was a case decided by the Supreme Court of the United States
regarding personal jurisdiction in the context of assets held in trust.
trust
was created by Mrs. Donner, who lived in Pennsylvania
. The trust was incorporated
in Delaware
, and a Delaware bank
was the trustee
. Donner later changed her state of domicile upon moving to Florida
where she eventually died. The will was admitted to probate
in Florida, and the court addressed the question of whether the Florida court or the Delaware trustee had jurisdiction over the trust.
test that had developed over the course of several decades of Supreme Court Jurisprudence. The trust company had no substantial business with Florida and no offices in Florida. The only contact with Florida was the fact that Donner moved there, which was ruled insufficient to support jurisdiction.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
regarding personal jurisdiction in the context of assets held in trust.
Factual background
A familyFamily
In human context, a family is a group of people affiliated by consanguinity, affinity, or co-residence. In most societies it is the principal institution for the socialization of children...
trust
Trust law
In common law legal systems, a trust is a relationship whereby property is held by one party for the benefit of another...
was created by Mrs. Donner, who lived in Pennsylvania
Pennsylvania
The Commonwealth of Pennsylvania is a U.S. state that is located in the Northeastern and Mid-Atlantic regions of the United States. The state borders Delaware and Maryland to the south, West Virginia to the southwest, Ohio to the west, New York and Ontario, Canada, to the north, and New Jersey to...
. The trust was incorporated
Incorporation
Incorporation may refer to:* Incorporation , the creation of a corporation* Incorporation of a place, creation of municipal corporation such as a city or county...
in Delaware
Delaware
Delaware is a U.S. state located on the Atlantic Coast in the Mid-Atlantic region of the United States. It is bordered to the south and west by Maryland, and to the north by Pennsylvania...
, and a Delaware bank
Bank
A bank is a financial institution that serves as a financial intermediary. The term "bank" may refer to one of several related types of entities:...
was the trustee
Trustee
Trustee is a legal term which, in its broadest sense, can refer to any person who holds property, authority, or a position of trust or responsibility for the benefit of another...
. Donner later changed her state of domicile upon moving to Florida
Florida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
where she eventually died. The will was admitted to probate
Probate
Probate is the legal process of administering the estate of a deceased person by resolving all claims and distributing the deceased person's property under the valid will. A probate court decides the validity of a testator's will...
in Florida, and the court addressed the question of whether the Florida court or the Delaware trustee had jurisdiction over the trust.
Decision
The Court decided that the Florida court lacked jurisdiction based on the minimum contactsMinimum contacts
Minimum contacts is a term used in the United States law of civil procedure to determine when it is appropriate for a court in one state to assert personal jurisdiction over a defendant from another state...
test that had developed over the course of several decades of Supreme Court Jurisprudence. The trust company had no substantial business with Florida and no offices in Florida. The only contact with Florida was the fact that Donner moved there, which was ruled insufficient to support jurisdiction.