International Shoe v. Washington
Citation: 326 U.S. 310 (1945)
Facts
International Shoe Company, a Delaware corporation with its principal place of business in Missouri, employed salespeople in Washington State who solicited orders for shoes. Washington sought to collect unemployment compensation taxes from the company. International Shoe challenged personal jurisdiction, arguing it was not “present” in Washington.
Issue
Does due process require physical presence for personal jurisdiction, or is something less sufficient?
Holding
Due process is satisfied when a non-resident defendant has “minimum contacts” with the forum state such that the exercise of personal jurisdiction does not offend “traditional notions of fair play and substantial justice.”
Rule
Minimum contacts test: A court may exercise personal jurisdiction over a non-resident defendant if the defendant has sufficient minimum contacts with the forum state so that (1) the defendant could reasonably anticipate being haled into court there, and (2) the exercise of jurisdiction comports with fair play and substantial justice.
- General jurisdiction: defendant’s contacts are so continuous and systematic that the defendant is essentially at home in the forum (subject to suit on any claim)
- Specific jurisdiction: the claim arises out of or is related to the defendant’s contacts with the forum
Significance
- Replaced the outdated Pennoyer v. Neff physical presence / territoriality framework with a flexible contacts-based analysis
- Foundational personal jurisdiction case; all subsequent cases build on its minimum contacts framework
- Key factors: purposeful availment of the forum, foreseeability of suit, relatedness of contacts to the claim, reasonableness