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 ProcedureAssigned 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.
Test yourself
Question 1 of 5
What was International Shoe's connection to the State of Washington?
The opinion states International Shoe had no office, stock, or contracts in Washington; its only connection was salesmen soliciting orders and displaying samples there.
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On the exam
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Other issues in this opinion
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