Can Florida courts exercise jurisdiction over out-of-state defendants in a dispute concerning a Delaware trust agreement and power of appointment, when the trust's settlor subsequently established domicile in Florida?

Dora Browning Donner, originally from Pennsylvania, established a trust in Delaware in 1935 with Wilmington Trust Co. as trustee. The trust contained securities, with Donner retaining lifetime income and power of appointment over the remainder. In 1944, Donner relocated to Florida, where she remained until her death in 1952. While in Florida in 1949, Donner executed a power of appointment, allocating $400,000 to trusts for her grandchildren, and a will with a residuary clause for property not effectively appointed. Following Donner's death, legatees under her will contested the validity of the trust and power of appointment in Florida courts. The Delaware trustee and certain beneficiaries were not personally served in the Florida legal proceedings.

Legatees initiated a suit for declaratory judgment in Florida chancery court. The court served some defendants personally, while others, including the Delaware trustee, received notification by mail and publication. Initially, the Florida chancellor dismissed the case, citing lack of jurisdiction over nonresident defendants. The legatees appealed this decision to the Florida Supreme Court, which reversed the lower court's ruling, determining that the court did indeed have jurisdiction.

Concurrently, the executrix filed a separate declaratory judgment action in Delaware. The Delaware court issued a ruling upholding the validity of the trust and power of appointment.

The case ultimately reached the U.S. Supreme Court, which was tasked with considering both the Florida and Delaware judgments in its deliberations.

(Warren, C.J.)

No. Florida courts cannot exercise jurisdiction over out-of-state defendants in this dispute concerning a Delaware trust agreement and power of appointment. Personal jurisdiction over nonresident trustees requires sufficient minimum contacts with the forum state, which are absent in this case. The mere fact that the settlor subsequently established domicile in Florida does not create the necessary connection to justify jurisdiction over out-of-state trustees or trust assets.

The Due Process Clause of the Fourteenth Amendment limits a state's power to exercise jurisdiction over nonresident defendants. International Shoe Co. v. Washington established that defendants must have certain minimum contacts with the forum state such that maintenance of the suit does not offend traditional notions of fair play and substantial justice. These minimum contacts must stem from some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum state, thus invoking the benefits and protections of its laws.

In this case, the trustees' contacts with Florida are insufficient to meet this standard. The trust agreement was executed in Delaware by a settlor then domiciled in Pennsylvania, the trustees are domiciled in Delaware, and the trust assets are located in Delaware. The settlor's unilateral act of moving to Florida after executing the trust does not create the necessary minimum contacts between the trustees and Florida. Furthermore, the trust agreement and its assets have remained in Delaware, outside Florida's territorial reach.

The principle of territorial jurisdiction limits a state's power to exercise jurisdiction over persons and property outside its territory. While exceptions exist for in rem jurisdiction over property within a state's borders, Florida cannot claim jurisdiction over trust assets located entirely in Delaware. The Full Faith and Credit Clause requires Florida to respect Delaware's valid judgment regarding the trust, as Delaware has proper jurisdiction over the trustees and trust assets within its borders.

This decision reinforces the importance of predictable jurisdictional rules in interstate trust administration. It protects trustees from being haled into court in any state where a settlor or beneficiary might later establish domicile, absent purposeful availment of that state's laws by the trustees themselves.

Dissent (Black, J.) Florida has sufficient interest and connections to adjudicate this controversy. The state's role in probating the will and administering the estate provides a compelling basis for jurisdiction. This case raises important questions about the extent of state authority in matters closely tied to probate proceedings, even when trust assets are held out of state. The majority's narrow view of jurisdiction unduly restricts states' ability to protect the interests of their deceased residents and their beneficiaries.

Dissent (Douglas, J.) Florida clearly has jurisdiction due to the close connection between the trustee and the deceased. The trustee should be viewed as a stakeholder or agent of the settlor, which establishes a sufficient nexus for Florida's courts to adjudicate this matter. This interpretation better aligns with the practical realities of trust administration and ensures that states can effectively oversee the disposition of assets closely linked to their residents, regardless of the technical location of those assets.

Dissent (Burton, J.) Concurred with Justice Black's dissent without providing a separate written opinion.

Dissent (Brennan, J.) Concurred with Justice Black's dissent without providing a separate written opinion.