McGee v. International Life Ins. Co

In McGee v. International Life Ins. Co. (1957) 355 U.S. 220, an insurance company in Texas solicited a California resident by mail to buy life insurance. The resident purchased a policy and mailed the premiums from California to Texas for six years, until his death. When the insurer refused to pay on the policy, the beneficiary filed suit in California and prevailed. The Supreme Court found that personal jurisdiction existed because the insurer had solicited the insured in California, delivered the policy in California, and accepted premiums mailed from California. Further, the event that triggered the policy's benefits--the insured's death--occurred in California. (Id. at pp. 222-223.) As the court held, "it is sufficient for purposes of due process that the suit was based on a contract which had substantial connection with the forum State." (Id. at p. 223 78 S. Ct. at p. 201.) The California resident (Franklin) purchased a life insurance policy from an Arizona insurance company. (Id. at p. 221.) After assuming the Arizona company's insurance obligations, a Texas insurance company "mailed a reinsurance certificate to Franklin in California offering to insure him in accordance with the terms of the policy he held with" the Arizona company, which he accepted. (Ibid.) After Franklin died, his mother, the beneficiary under the policy, sued the Texas company in California when the company refused to pay out the insurance proceeds because the company contended Franklin committed suicide. (Id. at p. 222.) The question of whether jurisdiction was proper in California under the due process clause ultimately ended up in the United States Supreme Court, and that court concluded that California properly asserted jurisdiction over the matter because "the suit was based on a contract which had a substantial connection with that State." (McGee v. International Life Ins. Co., supra, 355 U.S. at p. 223.) In reaching its decision, the court specifically noted as follows: "The contract was delivered in California, the premiums were mailed from there and the insured was a resident of that State when he died. It cannot be denied that California has a manifest interest in providing effective means of redress for its residents when their insurers refuse to pay claims. These residents would be at a severe disadvantage if they were forced to follow the insurance company to a distant State in order to hold it legally accountable. When claims were small or moderate individual claimants frequently could not afford the cost of bringing an action in a foreign forum--thus in effect making the company judgment proof. Often the crucial witnesses--as here on the company's defense of suicide--will be found in the insured's locality. Of course there may be inconvenience to the insurer if it is held amenable to suit in California where it had this contract but certainly nothing which amounts to a denial of due process." (Id. at pp. 223-224.)