International Shoe v. Washington
326 U.S. 310, 66 S. Ct. 154, 90 L. Ed. 95 (1945)
International Shoe Company was
incorporated in Delaware but did most of its business in Missouri. They
had a few salespeople in Washington to advertise their shoes.
The salespeople were only
given left shoes so they could not make a sale. This was done specifically
so International Shoe could argue that they didn't do business in
Under Washington law, all corporations in Washington had to pay into an unemployment
compensation fund. International Shoe didn't pay, Washington sued.
International Shoe argued
that Washington did not have jurisdiction.
The Due Process Clause protects an individual's liberty interest in
not being subject to the binding judgments of a forum with which he has
established no meaningful "contacts, ties or relations."
The US Supreme Court found for
The US Supreme Court found
that since the salespeople lived in Washington, and their principle
activity in Washington was to the benefit of the company, and the company
was paying them, that's proof that Washington does have jurisdiction over
The Court found that a
corporation must have minimum contacts in a State for the State to have jurisdiction.
The standard for minimum
contacts is that the activities of
the corporation have been continuous and systematic in the State, and the cause of action must
have arisen out of that activity.
The Court found that within
a Federal system, the suit could be brought as long as it did not offend
traditional notions of fair play
and substantial justice.
That's a very subjective
Washington did not make the
argument that the salesmen could have theoretically made sales to