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US Civil Procedure for International Students: 2020 - 2021 Edition

Hanson v. Denckla

In Hanson v. Denckla, a wealthy woman named Donner died, and her family ended up in litigation as to who would receive the money she left behind. While she was alive and living in Pennsylvania, she created a trust, using a Delaware bank as the trustee. Later, Mrs. Donner moved to Florida, which became her state of domicile, and she eventually died in Florida. The Delaware Trustee processed the existing trust after Mrs. Donner moved to Florida, but appears not to have sought or obtained additional business. After her death, her estate went to probate in Florida (probate being the process by which a state disposes of the assets of a person who had died). Ultimately, the Florida court held that it had jurisdiction over the Delaware trustee, and entered judgment disposing of the assets of the trust (the effect being to give extra money to Mrs. Donner's two surviving daughters and none to two granddaughters who were the daughters of a third daughter who had died before Mrs. Donner). Meanwhile, separate litigation began in Delaware, and it reached a result that would give the money in the trust to the two granddaughters. If the Florida court had proper jurisdiction over the trustee, its decision would control under the Full Faith and Credit Clause because its judgment had been reached first (and that lawsuit filed first). The two sets of litigation reached the Supreme Court together.