Don't Mess With Illinois

The minimum contacts standard helps us determine whether a state can assert jurisdiction over a non-resident. If a non-resident has not established minimum contact, they must be served in person within the state. In today's cases, we'll see the minimum contacts standard being expanded. As communication and transportation became more efficient, SCOTUS made it easier to sue out of state residents and companies.

McGee v. International Life Insurance Company (1957)

Facts
Mr. McGee was a resident of California. He held a policy with International Life Insurance Company, which was based in Texas. Mr. McGee was most likely their only policy holder in California. They had no agencies within the state, and this particular policy was executed entirely by mail.

When McGee died, the company refused to pay out on his policy. They contended that the policy was void because he committed suicide. McGee's wife sued in California court. Notice of the suit was sent by registered mail to International Life. They did not appear in court, and Ms. McGee won by default.

The state of Texas then refused to give full faith and credit to the judgment. The state felt that due process was not served.

Question
Did International Life Insurance Company establish minimum contact within the state of California?

Holding
Yes

Reasoning
The policy holder was a resident of California. The policy was delivered in California. The premiums were paid in California.

And the winner is...
Ms. Mcgee

Gray v. American Radiator

Facts
Illinois adopted long-arm statutes. Long-arm statutes mean that the state will aggressively try to assert jurisdiction on non-residents as often as possible.

Gray purchased a water heater in his home state of Illinois. The water heater exploded and Gray sued American Radiator. Also named in the suit was Titan Valve, who allegedly manufactured the defective part. Titan was an Ohio based company who sold the part to American Radiator in Pennsylvania. Titan never did business in Illinois.

Question
Do Illinois' long-arm statutes give them the right to assert jurisdiction over Titan?

Holding
Yes

Reasoning
The U.S. economy is made up of middlemen. Once Titan's products entered the stream of commerce, the company was responsible for them regardless of where they ended up.

And the winner is...
Gray

summarized from Life of a Law Student