Washington sought to collect unpaid contributions to its unemployment compensation fund from International Shoe, a Delaware corporation headquartered in Missouri. The company had no office, inventory, or contracts in Washington, but it employed 11 to 13 salesmen who resided there, solicited orders there continuously, displayed samples, and sometimes rented sample rooms, with commissions exceeding $31,000 annually. Orders were sent to St. Louis for acceptance, and goods were shipped into Washington from outside the state. Washington served notice on a local salesman and by registered mail to Missouri, and the state tribunals upheld the assessment.
Did Washington, consistent with the Due Process Clause, have personal jurisdiction over International Shoe and authority to require it to pay unemployment compensation contributions based on its activities in the state?
A state may exercise in personam jurisdiction over a nonresident defendant when the defendant has certain minimum contacts with the forum such that maintaining the suit does not offend traditional notions of fair play and substantial justice. Continuous and systematic activities in the forum that give rise to the obligation sued on are sufficient.
Yes. International Shoe's activities in Washington were sufficient to subject it to suit there, and Washington could require payment of the unemployment compensation contributions without violating due process.
The Court rejected the older fiction that jurisdiction depends on a corporation's literal "presence" and instead focused on the quality and nature of the corporation's contacts with the forum. International Shoe's solicitation in Washington was regular, systematic, and continuous, and it directly generated a substantial flow of business in the state over several years. Because the tax obligation arose from those in-state activities, requiring the company to defend in Washington was reasonable and fair. The Court also noted that Congress had authorized state unemployment assessments affecting interstate commerce, removing any serious Commerce Clause obstacle.
This is the foundational modern personal-jurisdiction case. It replaced rigid territorial concepts associated with Pennoyer v. Neff, 95 U.S. 714 (1878), with the "minimum contacts" and "fair play and substantial justice" framework that governs due process analysis for personal jurisdiction. It underlies later distinctions between specific and general jurisdiction in cases such as McGee v. International Life Insurance Co., 355 U.S. 220 (1957), Hanson v. Denckla, 357 U.S. 235 (1958), World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980), Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985), Helicopteros Nacionales de Colombia, S. A. v. Hall, 466 U.S. 408 (1984), Goodyear Dunlop Tires Operations, S. A. v. Brown, 564 U.S. 915 (2011), and Daimler AG v. Bauman, 571 U.S. 117 (2014).
Pennoyer v. Neff, 95 U.S. 714 (1878) |
Verified |
McGee v. International Life Insurance Co., 355 U.S. 220 (1957) |
Verified |
Hanson v. Denckla, 357 U.S. 235 (1958) |
Verified |
World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) |
Verified |
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) |
Abstain |
S. A. v. Hall, 466 U.S. 408 (1984) |
Abstain |
S. A. v. Brown, 564 U.S. 915 (2011) |
Verified |
Daimler AG v. Bauman, 571 U.S. 117 (2014) |
Abstain |
Enter a case name or citation — get a structured brief where every case it cites is checked against real law.
Try Law Student Workbench →