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 Washington.
  • 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 Washington.
    • 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 corporation.
    • 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 standard.
    • Washington did not make the argument that the salesmen could have theoretically made sales to one-legged people.