McGee v. International Life Ins. Co., 355 U.S. 220 (1957)
To satisfy due process, a contract suit must be based on a contract that has a substantial connection with the forum for it to have personal jurisdiction over a non-resident defendant.
After Lowell Franklin bought a life insurance policy from an insurer, it was reinsured by International Life Insurance Co. The reinsurer mailed a reinsurance certificate to Franklin, who lived in California, and offered to insure him. Accepting this offer, Franklin mailed all payments for his premiums from his residence in California to International's office in Texas. Once Franklin died, the beneficiary of his policy, McGee, informed International of his death. International refused to pay the proceeds of the policy, and McGee successfully sued it in California.Opinions
- Hugo Lafayette Black (Author)
- Earl Warren
- William Orville Douglas
- Harold Hitz Burton
- Tom C. Clark
- Felix Frankfurter
- John Marshall Harlan II
- William Joseph Brennan, Jr.
- Charles Evans Whittaker
There were substantial connections between California and the subject matter of the lawsuit, since both the policy holder and the beneficiary lived in California, the contract was sent there, and the premiums were payable there. As the forum state, California has a strong interest in providing remedies for residents when their insurers fail to properly pay out claims. They should not be required to litigate their claims in a distant state.Case Commentary
The court found that soliciting the policy in California, even though only a single occurrence, was a sufficient contact to find that California jurisdiction was foreseeable. It might have reached a different outcome if the insured party had bought the policy in Texas and moved to California.
U.S. Supreme CourtMcGee v. International Life Ins. Co., 355 U.S. 220 (1957)
McGee v. International Life Ins. Co.
Argued November 20, 1957
Decided December 16, 1957
355 U.S. 220
Petitioner's son, a resident of California, bought a life insurance policy from an Arizona corporation, naming petitioner as beneficiary. Later, respondent, a Texas corporation, agreed to assume the insurance obligations of the Arizona corporation, and mailed a reinsurance certificate to petitioner's son in California, offering to insure him in accordance with his policy. He accepted this offer, and paid premiums by mail from his California home to respondent's office in Texas. Neither corporation has ever had any office or agent in California or done any other business in that State. Petitioner sent proofs of her son's death to respondent, but it refused to pay the claim. Under a California statute subjecting foreign corporations to suit in California on insurance contracts with residents of California, even though such corporations cannot be served with process within the State, petitioner sued respondent and obtained judgment in a California court, process being served only by registered mail to respondent's principal place of business in Texas.
1. The Due Process Clause of the Fourteenth Amendment did not preclude the California court from entering a judgment binding on respondent, since the suit was based on a contract which had a substantial connection with California. Pp. 355 U. S. 223-224.
2. Respondent's insurance contract was not unconstitutionally impaired by the fact that the California statute here involved did not become effective until after respondent had assumed the obligation of the insurance policy. P. 355 U. S. 224.
288 S.W.2d 579, reversed and remanded.