Friday, February 8, 2013

Hanson v. Denckla case brief

Hanson v. Denckla
357 U.S. 235

SYNOPSIS: The court granted certiorari to a decision from the Delaware Supreme Court where the executrix of the subject estate appealed a judgment from the Supreme Court of Florida in consolidated cases concerning rights to part of the corpus of a trust established in Delaware by a settlor who later became domiciled in Florida. The papers whereon appeal was taken from the Florida judgment were treated as a petition for certiorari, which was granted.


-Mrs. Donner, a Pennsylvania resident, established a trust in Delaware naming a Delaware bank as trustee.
-Donner was the income beneficiary of the trust during her lifetime and the remainder was to go to her beneficiary. -Donner moved to Florida and drafted a will naming her daughters (“Hanson”, P) as her primary heirs.
-Two grandchildren, the daughters of Donner’s third daughter, were named as the beneficiaries of the trust.
-Donner died and Hanson brought suit in Florida seeking to have the balance of the trust fund placed into the estate for probate on the grounds that the appointment of Donner’s grandchildren as beneficiaries was invalid.
-While that suit was pending another suit was filed in Delaware to determine the status of the trust.
-In consolidated cases, the parties contested the trust assets that were located in Delaware.

The court held that Florida acquired no in rem jurisdiction to adjudicate the validity of the inter vivos dispositions simply because its decision might augment an estate passing under a will probated in its courts.

The fact that the owner was domiciled in Florida was not a sufficient affiliation with the property upon which to base jurisdiction in rem. Finding that Florida had no in rem jurisdiction, the court held that a judgment purporting to rest on that basis was invalid in Florida and must be reversed. Florida additionally had no in personam jurisdiction over the Delaware trustee. Since Florida was forbidden to enter a judgment attempting to bind a person over whom it had no jurisdiction, it had even less right to enter a judgment purporting to extinguish the interest of such a person in property over which the court had no jurisdiction. The unilateral activity of those who claimed some relationship with the nonresident defendant could not satisfy the requirement of contact with Florida. The Florida judgment was invalid under the fourteenth amendment principles of the constitution.

OUTCOME: The Delaware judgment not to accord full faith and credit to the Florida decree was affirmed. The Florida judgment that the contested part of the corpus of the trust passed under the residuary clause of the settlor's will, which was admitted to probate in Florida, was reversed and remanded. Florida had no jurisdiction over the trust or the trustee and the resulting judgment was, therefore, invalid.

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