International Shoe Co. v. Washington
Citation: 326 U.S. 310 (U.S. Supreme Court, 1945)
Facts
International Shoe was a Delaware corporation with its principal place of business in Missouri. It had no office in Washington but employed a dozen salespeople there who solicited orders and occasionally rented space to display merchandise. Washington sought to collect unpaid contributions to its unemployment compensation fund. International Shoe argued Washington lacked personal jurisdiction over it.
Issue
Whether a state may exercise personal jurisdiction over a foreign corporation that has no office or agent in the state but conducts systematic and continuous business activities there through its employees.
Holding
The Supreme Court held that Washington could exercise personal jurisdiction over International Shoe because the company’s activities in the state were systematic and continuous, rendering it fair and reasonable to require it to defend a suit arising from those activities in Washington.
Rule
Due process requires that a defendant have minimum contacts with the forum state such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice. The quality and nature of the contacts, not their quantity alone, determine whether jurisdiction is constitutionally permissible.
Significance
International Shoe is the most important personal jurisdiction case ever decided. It replaced the rigid territorial power theory of Pennoyer v. Neff with a flexible due process framework based on minimum contacts and fairness, and forms the foundation of all modern personal jurisdiction analysis.