International Shoe Co. v. Washington - Case Brief
International Shoe v. Washington, 326 U.S. 310 (1945).
Case Summary
Facts: International Shoe Co. (D, appellant) was a Delaware corporation with its principle place of business in St. Louis, Missouri. It had no offices in the state of Washington and made no contracts for sale there. International Shoe did not keep merchandise in Washington and did not make deliveries of goods in intrastate commerce originating from the state.
International Shoe employed 11-13 salesmen for three years who resided in Washington. Their commissions each year totaled more than $31,000 and International Shoe reimbursed them for expenses. Prices, terms, and acceptance or rejection of footwear orders were established through St. Louis. Salesmen did not have authority to make contracts or collections. International Shoe was sued in Washington State court to recover unpaid contributions to the state’s unemployment compensation fund. Notice was served personally on an agent within the state and by registered mail to the corporation’s headquarters. The Supreme Court of Washington held that the state had jurisdiction to hear the case and International Shoe appealed.
Issue: Did International Shoe’s activities in Washington make it subject to personal jurisdiction in Washington courts?
Holding: Yes. Minimum contacts with the forum state can give a court in that state personal jurisdiction over a party without violating the Due Process clause.
Rule: A casual presence of a corporation or its agent in a state in single or isolated incidents is not enough to establish jurisdiction. Acts of agents of the corporation, because of the nature, quality, and circumstances of their commission, may be deemed sufficient. Consent may be implied from the corporation’s presence and activities in the state through the acts of authorized agents.
The activities carried on by appellant in Washington were systematic and continuous rather than irregular or casual. D received the benefits and protection of the laws of the state and is subject to jurisdiction there.
Relevant factors: International Shoe had conducted “systematic and continuous” business in Washington. A large volume of interstate business for the defendant was created through D’s agents in the state and D received the benefits and protection of the state’s laws. D had established agents in the state permanently.
Disposition: Affirmed.
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