International Shoe Co. v. Washington
326 U.S. 310 · Supreme Court of the United States · 1945
Facts
International Shoe, a Delaware corporation, employed 11-13 salesmen in Washington to solicit orders, display samples, and transmit orders to its Missouri office for acceptance. Washington assessed unemployment compensation contributions, serving notice on a salesman and mailing it to Missouri. International Shoe challenged jurisdiction, arguing it lacked sufficient contacts with Washington.
Issue
Can a state assert personal jurisdiction over a foreign corporation and collect unemployment contributions consistent with the Due Process Clause of the Fourteenth Amendment, when the corporation's only contacts are continuous and systematic solicitation by resident salesmen?
Holding
Yes. The Supreme Court affirmed the Washington Supreme Court's decision, finding that International Shoe's continuous and systematic activities in Washington were sufficient to establish minimum contacts for personal jurisdiction and taxation.
Rule
For a state to assert personal jurisdiction over a foreign corporation, due process requires that the corporation have "certain minimum contacts" with the state such that the maintenance of the suit "does not offend traditional notions of fair play and substantial justice." These contacts must be systematic and continuous, and the obligation sued upon must arise out of or be connected with those activities.
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