## Facts

- A California resident bought a life insurance policy from an Arizona insurer and named his mother, also a California resident, as beneficiary.
- A Texas insurer assumed the policy obligations and mailed a reinsurance certificate to the insured in California offering coverage on the existing terms.
- The insured accepted and paid premiums by mail from California to the insurer’s Texas office until his death.
- The insurer had no office or agents in California and conducted no other business there besides this policy relationship.
- After the insured died, the beneficiary submitted proof of death, and the insurer refused to pay, asserting suicide.
- The beneficiary sued the insurer in California state court under a statute permitting suit against foreign insurers on policies with California residents; service was by registered mail to the insurer in Texas.
- The California court entered a default judgment for the beneficiary.
- When the beneficiary sought to enforce the judgment in Texas, a Texas appellate court refused, concluding California lacked personal jurisdiction over the insurer.
- The Supreme Court reviewed whether California’s exercise of personal jurisdiction comported with due process and whether the California judgment must be honored.

## Issues

1. Whether due process permits a state to exercise personal jurisdiction over a nonresident insurer with no offices, agents, or other business in the forum, based on a single insurance contract with a forum resident.
2. Whether the forum connections of the contract and the state’s interest in providing a remedy make jurisdiction consistent with “fair play and substantial justice.”
3. Whether the resulting forum judgment is entitled to recognition and enforcement in another state.

## Decision

- The Court held that California’s exercise of jurisdiction over the Texas insurer did not violate the Due Process Clause.
- The Court concluded it was sufficient that the suit arose from a contract with a substantial connection to California.
- The Court emphasized that the policy relationship was purposefully directed to California: delivery of the reinsurance certificate there, premium payments mailed from there, and the insured’s California residency at death.
- The Court credited California’s strong interest in providing effective redress for residents when insurers refuse to pay claims.
- The Court reasoned that modern transportation and communication reduced the burden of defending in a distant forum.
- The Texas court’s refusal to enforce the California judgment was reversed and the case was remanded.

## Legal Principles

- Specific jurisdiction satisfies due process when the cause of action arises out of a contract that has substantial connections with the forum state.
- A single, forum-related contractual relationship can constitute sufficient minimum contacts when the defendant deliberately enters or continues that relationship with a forum resident and the claim arises from it.
- In assessing fairness, courts consider the forum state’s interest in providing a remedy for residents and the practical burdens of out-of-state litigation in modern commerce.
- A judgment rendered with constitutionally adequate personal jurisdiction is entitled to enforcement in other states.

## Conclusion

The Court upheld California’s jurisdiction over an out-of-state insurer based on one insurance contract substantially connected to California, reinforcing that targeted forum-related conduct supporting the claim can satisfy due process and require interstate enforcement of the resulting judgment.


McGee v. Int'l Life Ins. Co., 355 U.S. 220 (1957)