McGee (plaintiff)
v.
International Life Insurance Co. (defendant)
78 S. Ct. 199 • 1957
Facts:
Plaintiff McGee lives in California and was the beneficiary of a life-insurance policy underwritten by defendant International Life Insurance Co.
International Life Insurance Co. refused to pay on the claim.
International Life Insurance Co. did no business in California other than the policy with McGee. The two parties exchanged mailings on a regular basis for many years.
Procedure:
McGee sues International Life Insurance Co. in California court and wins a judgment against it.
McGee attempts to enforce the California judgment in Texas. The Texas court refuses to enforce the judgment.
Case is appealed to the Supreme Court.
Issue:
Does a California court have jurisdiction over a foreign insurance company when the company transacted business with a resident there through the mail but had no other contacts with the state?
Holding:
Yes.
Reasoning:
We live in a time of increased nationalization of commerce. There is a trend toward expanding the scope of a state’s jurisdiction over nonresidents.
The company’s right to due process is not violated because the suit was based on a contract with substantial connection to the state: premiums were mailed from there, the contract was delivered there, and the insured was a resident of there.
California has an interest in providing its residents the means of redress.
In the case of insurance claims, it is often difficult for a plaintiff to bring his case in a foreign state because of practical reasons. We do not want to thus declare insures judgment proof.
Balancing this against the insurer’s right to due process, it is not inconvenient for the insurer to be amenable to suit in California.
v.
International Life Insurance Co. (defendant)
78 S. Ct. 199 • 1957
Facts:
Plaintiff McGee lives in California and was the beneficiary of a life-insurance policy underwritten by defendant International Life Insurance Co.
International Life Insurance Co. refused to pay on the claim.
International Life Insurance Co. did no business in California other than the policy with McGee. The two parties exchanged mailings on a regular basis for many years.
Procedure:
McGee sues International Life Insurance Co. in California court and wins a judgment against it.
McGee attempts to enforce the California judgment in Texas. The Texas court refuses to enforce the judgment.
Case is appealed to the Supreme Court.
Issue:
Does a California court have jurisdiction over a foreign insurance company when the company transacted business with a resident there through the mail but had no other contacts with the state?
Holding:
Yes.
Reasoning:
We live in a time of increased nationalization of commerce. There is a trend toward expanding the scope of a state’s jurisdiction over nonresidents.
The company’s right to due process is not violated because the suit was based on a contract with substantial connection to the state: premiums were mailed from there, the contract was delivered there, and the insured was a resident of there.
California has an interest in providing its residents the means of redress.
In the case of insurance claims, it is often difficult for a plaintiff to bring his case in a foreign state because of practical reasons. We do not want to thus declare insures judgment proof.
Balancing this against the insurer’s right to due process, it is not inconvenient for the insurer to be amenable to suit in California.