McGee v. International Life Insurance Co., 355 U.S. 220 (1957)
McGee v. International Life Insurance Co.
Whether California's exercise of specific personal jurisdiction over a Texas insurer, based on a single insurance contract with a California resident and premiums paid by mail, comported with due process; and, if so, whether Texas was required under the Full Faith and Credit Clause to enforce the California default judgment.
Under International Shoe, a state may exercise specific personal jurisdiction over a nonresident defendant when the defendant has minimum contacts with the forum such that the suit does not offend traditional notions of fair play and substantial justice. When the cause of action arises out of a contract that has a substantial connection with the forum state, and the forum has a strong interest in providing a convenient forum for its residents, even a single, isolated contact may satisfy due process. If the rendering state had personal jurisdiction consistent with due process, sister states must give full faith and credit to the resulting judgment, including default judgments.
Yes. California's assertion of specific personal jurisdiction over International Life was consistent with due process because the insurance contract had a substantial connection with California and the claim arose from that contact. Consequently, Texas was constitutionally required to give full faith and credit to the California judgment.
McGee is a cornerstone of specific jurisdiction doctrine. It confirms that one meaningful, forum-centered transaction can establish minimum contacts when the claim arises from that transaction and the forum's interest and fairness concerns favor jurisdiction. The case validated state long-arm statutes, particularly in consumer and insurance contexts, and underscored the interplay between due process and the Full Faith and Credit Clause in enforcing judgments across state lines. Although later decisions—especially Hanson v. Denckla—added the purposeful availment requirement and curtailed any overreading of McGee, the case remains vital for understanding single-contact jurisdiction and the relatedness requirement central to modern personal jurisdiction jurisprudence.