Tags: Personal jurisdiction, in rem jurisdiction
See also: McGee v. International Life Ins. Co., International Shoe
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The case of Hanson, Executrix, et al. v. Denckla et al. involves a dispute over the right to $400,000 from a trust established by a settlor who moved from Delaware to Florida. One group of claimants argues that the property passed under the settlor's will, while another group argues that it passed through the settlor's exercise of an inter vivos power of appointment. The Florida courts have supported the former, while the Delaware courts have supported the latter. The issue of jurisdiction was postponed in the Florida appeal and certiorari was granted to the Delaware Supreme Court.
The controversy arises from the residuary clause that created the trusts. The residuary clause in Mrs. Donner's will directs her executrix to deal with all the remaining property, including any property over which she had a power of appointment that was not effectively exercised before her death or was exercised in favor of her executrix. Residuary legatees Denckla and Stewart are seeking a declaratory judgment on the property that passes under the residuary clause of Mrs. Donner's will.
The case was brought before a Florida chancery court, but the Chancellor ruled that he lacked jurisdiction over the trustees and dismissed the case as to them. However, he ruled that the power of appointment was void under Florida law and that the $400,000 passed under the residuary clause of the will. The executrix filed a declaratory judgment action in Delaware, and the Delaware Chancellor ruled that the trust and power of appointment were valid under Delaware law and that the trust corpus had been properly paid to the Delaware Trust Co. and other appointees. The Florida decree was not considered res judicata in the Delaware dispute.
The Florida Supreme Court found the trust invalid and ruled that jurisdiction over absent defendants existed. The Florida Appeal case questions the constitutionality of a Florida statute providing for constructive service. The appellants argue that the Florida court lacked jurisdiction, violating the Due Process Clause of the Fourteenth Amendment. The judgment based on this jurisdiction is invalid and must be reversed. The court lacks personal jurisdiction over the nonresident Delaware trustee in Florida. The Delaware Supreme Court's decision is upheld, but the Florida Supreme Court's decision is overturned and sent back for further proceedings. Florida has jurisdiction to determine the validity of Mrs. Donner's appointment against its statute of wills as the appointment had close connections with Florida. The trustee of the trust was in privity with the deceased and had a community of interest with her. Therefore, Florida could make the controlling determination even without personal service over the trustee and those who claim under it.
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