International Shoe v. Washington

International Shoe Co. v. Washington
Supreme Court of the United States
Argued November 14, 1945 Decided December 3, 1945
Full case name	International Shoe Company v. State of Washington, Office of Unemployment Compensation & Placement, et al.
Citations	326 U.S. 310 (more) 66 S. Ct. 154; 90 L. Ed. 95; 1945 U.S. LEXIS 1447; 161 A.L.R. 1057
Prior history	Special appearance by appellant in Washington state court as defendant in lower court; appellant moved to set aside order on grounds of lack of personal jurisdiction; tribunal denied motion; state Superior Court affirmed; state Supreme Court affirmed
Holding
Suit cannot be brought against an individual unless they have minimum contacts with the forum state, and such lawsuit does not offend traditional notions of fair play and substantial justice.
Court membership
Case opinions
Majority	Stone, joined by Reed, Frankfurter, Douglas, Murphy, Rutledge, Burton
Concurrence	Black
Jackson took no part in the consideration or decision of the case.
Laws applied
U.S. Const. Amendment XIV

International Shoe Co. v. Washington, 326 U.S. 310 (1945), was a landmark decision of the Supreme Court of the United States in which the Court held that a party, particularly a corporation, may be subject to the jurisdiction of a state court if it has "minimum contacts" with that state. The ruling has important consequences for corporations involved in interstate commerce, their payments to state unemployment compensation funds, limits on the power of states imposed by the Due Process Clause of the Fourteenth Amendment, the sufficiency of service of process, and, especially, personal jurisdiction.

The plaintiff, the State of Washington, established a tax on employers conducting business therein with the stated legislative purpose of providing a fund to be used for financial assistance to newly unemployed workers in the state. The tax was in effect a mandatory contribution to the state's Unemployment Compensation Fund. The defendant, International Shoe Co., was an American company that was incorporated in Delaware with its principal place of business ("PPB") in Missouri. The corporation had maintained for some time a staff of 11-13 salesmen in the State of Washington, working on commission. The salesmen were residents of that state and they met with prospective customers in motels and hotels, and occasionally rented space to put up displays. The company thus had no permanent "situs" of business in the State. Each year, the salesmen brought in about $31,000 in compensation. International Shoe's solicitation system allegedly was set up explicitly to avoid establishing the situs of the business in other states insofar as salesman did not have offices, did not negotiate prices, and sent all orders back to Missouri; shipments from the plant to customers were sent f.o.b..