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International Shoe v. Washington

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International Shoe Co. v. Washington, 326 U.S. 310, 66 S. Ct. 154, 90 L. Ed. 95 (1945), is a landmark civil procedure case which the Supreme Court held that due process required that the defendant have "certain minimum contacts" with the forum in order for a state to assert jurisdiction, and that such jurisdiction may not offend "traditional notions of fair play and substantial justice."

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Contents

Summary of Case Facts

Defendant (International Shoe Co.) was a Delaware corporation with its principle place of business in St. Louis, Missouri. Defendant made no contracts for sale, had no physical offices, and did not keep merchandise in the state of Washington (Plaintiff). Defendant employed salesmen for three years who resided in Washington. Each year their commissions totaled more than $31,000 and defendant reimbursed them for expenses. The state of Washington brought suit against defendant in Washington State court to recover unpaid mandatory contributions to the unemployment compensation fund. Notice was served personally on an agent of the defendant within the state of Washington and by registered mail to corporate headquarters. The Supreme Court of Washington held that the state had jurisdiction to hear the case and defendant appealed to the U.S. Supreme Court.

Issue

Whether International Shoe’s activities in Washington make it subject to personal jurisdiction in Washington courts.

Holding and Law

Yes. Minimum contacts with the forum state can enable a court in that state to exercise personal jurisdiction over a party consistent with the Due Process clause. The Supreme Court has set forth several criteria to be used in analyzing whether jurisdiction over a nonresident is proper. These criteria require that the defendant has purposefully availed himself or herself of the benefits of the state so as to reasonably foresee being haled into court in that state, that the forum state has sufficient interest in the dispute, and that haling the defendant into court does not offend "notions of fair play and substantial justice." International Shoe had conducted "systematic and continuous" business operations in the state of Washington. A large volume of interstate business for the defendant was created through it's agents within the state and the corporation received the benefits and protection of Washington’s laws. Also, International Shoe had established agents in the state permanently.

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