McGee v. Int'l Life Ins. Co

355 U.S. 220, 78 S. Ct. 199 (1957)

 

RULE:

When a state courts jurisdiction is based on a contract that has a substantial connection with another state, due process is satisfied. In other words, a state court can enforce a judgment from another state, if there are " minimum contacts" with their own state.

FACTS:

Lowell Franklin, a resident of California, purchased a life insurance policy from the Empire Mutual Insurance Company, an Texas corporation. In 1948, International Life Insurance Co. assumed Empire Mutual’s insurance obligations. Respondent then mailed a reinsurance certificate to Franklin in California offering to insure him in accordance with the terms of the policy he held with Empire Mutual. He accepted this offer and from that time until his death in 1950 paid premiums by mail from his California home to respondent's Texas office. Petitioner, Franklin's mother, was the beneficiary under the policy. She sent proofs of his death to the respondent but it refused to pay. The beneficiary obtained a judgment against the insurer in a California state court and attempted to enforce it through an action in the Texas state courts. The Texas courts refused to enforce the California judgment, holding that the judgment was void under the Fourteenth Amendment.

ISSUE:

Is the Texas court’s enforcement of the California court judgement a violation of due process under the Fourteenth Amendment?

ANSWER:

No.

CONCLUSION:

It was sufficient for purposes of the due process clause that the beneficiary's suit was based on a contract which had substantial connection with California. The contract was delivered in California, the premiums were mailed from there, and the insured was a resident of California when he died.

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