International Shoe Co. v. Washington

326 U.S. 310, 66 S. Ct. 154, 90 L. Ed. 95, 161 A.L.R. 1057 · Supreme Court of the United States · 1945

Civil Procedure Assigned in 23 casebooks

Case brief summary

Rule

A court can only rule against someone not present in the state if they have enough contact with that state to make being sued there fair.

Facts

International Shoe had no office in Washington but had salesmen there regularly selling products. Washington tried to collect unpaid unemployment fund payments based on those salesmen's wages.

Procedural history

Washington's agency ordered the company to pay, and it lost at every court level, including the state Supreme Court. The company then appealed to the U.S. Supreme Court.

Issue

Did Washington have the power to make the company face this lawsuit and tax it without violating the constitutional right to fair legal procedures?

Holding

Yes, the company's steady sales activity in Washington created enough contact to make the lawsuit fair, and the notice given was legally sufficient. The tax was valid too.

Reasoning

A company's legal presence in a state comes from its agents' activities there, not physical buildings. Since salesmen worked steadily in Washington and created the obligation being sued on, defending the suit there was fair.

Opinions

Majority (Stone): Continuous and systematic business activity in a state, connected to the claim, creates enough minimum contacts to allow a state to sue or tax a company there.

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What was International Shoe's connection to the State of Washington?

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What were the facts of this case regarding International Shoe's activities in Washington?
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