McGee v. International Life Ins. Co.

355 U.S. 220 (1957)

A 1957 United States Supreme Court opinion in the area of personal jurisdiction in which the Court held that a non-resident defendant’s single or isolated activities related to the controversy could support personal jurisdiction over that defendant.

The case commenced in a California state court and involved the claims of McGee, in her capacity beneficiary of her deceased son’s life insurance policy, against a non-resident insurance company, International Life.  International Life was served by mail in Texas, its corporate home.  International Life declined to appear in the case and McGee obtained a default judgment in California, which she later attempted to enforce in Texas.  In response to McGee’s judgment enforcement efforts, International Life collaterally attacked the judgment, contending that California did not have personal jurisdiction over it and, therefore, the judgment was void ab initio.  The Texas courts agreed and held that the judgment was void under the Fourteenth Amendment because service of process outside of California could not give the courts of that State jurisdiction over International Life.

The United States Supreme Court reversed the Texas court’s rulings and ruled that the California state court could exercise jurisdiction over International Life, notwithstanding the fact that the defendant conducted virtually no business in California, with the only California policy in force being the decedent’s (McGee’s son).  The Court emphasized the fact that the contract sued upon had a substantial connection to the forum state, as well as California’s strong interest in protecting its citizens.

See also Specific Jurisdiction

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