Hanson v. Denckla

Summary

The Supreme Court held that Florida lacked personal jurisdiction over the Delaware trustee and in rem jurisdiction over trust assets located in Delaware. Because the Florida court lacked jurisdiction over an indispensable party, its judgment was not entitled to full faith and credit, and the Delaware judgment was affirmed. The decision also explains the minimum-contacts requirement for personal jurisdiction and the limits of jurisdiction over out-of-state intangible property.

Holdings

1. The Court lacked appellate jurisdiction because the federal constitutional challenge presented in the Supreme Court was not raised below in the manner required for appellate review. The appeal was therefore dismissed, but the papers were treated as a petition for certiorari, which was granted.
2. Florida lacked in rem or quasi in rem jurisdiction over trust assets located in Delaware. A Florida probate proceeding, the settlor's Florida domicile, or the possibility that the assets might pass under a Florida will did not create the necessary territorial affiliation with property held in Delaware.
3. Florida lacked personal jurisdiction over the Delaware trustee because the trustee lacked the minimum contacts with Florida required by the Due Process Clause.
4. Because Florida law required the trustee to be an indispensable party in litigation affecting the validity of the trust, and Florida lacked jurisdiction over the trustee, the Florida court could not adjudicate the controversy even as to parties over whom it otherwise had jurisdiction.
5. Delaware was not required to give full faith and credit to the Florida judgment because the Florida judgment was constitutionally invalid for lack of jurisdiction over the Delaware trustee and the trust res.

Questions Presented

1. Whether Florida had in rem jurisdiction over trust assets held in Delaware based on the settlor's Florida domicile, Florida probate proceedings, or the possibility that the assets would pass under a Florida will.
2. Whether Florida had in personam jurisdiction over the nonresident Delaware trustee consistent with the Due Process Clause of the Fourteenth Amendment.
3. Whether the Delaware courts were required by the Full Faith and Credit Clause and 28 U.S.C. § 1738 to recognize the Florida judgment.
4. Whether the Supreme Court had appellate jurisdiction over the Florida judgment when the federal jurisdictional objection had not been properly presented below.

Disposition

reversed_and_remanded