International Shoe Co. v. Washington – Case Brief Summary

Summary of International Shoe Co. v. Washington, 326 U.S. 310, 66 S. Ct. 154, 90 L. Ed. 95 (1945).

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.

The state of Washington brought suit against International Shoe in Washington State court to recover unpaid contributions to the unemployment compensation fund. Notice was served personally on an agent of the defendant within the state and by registered mail to corporate 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 and Rule (Stone)

  • Yes. Minimum contacts with the forum state can enable a court in that state to exert personal jurisdiction over a party consistent with the Due Process clause.

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 defendant corporation in Washington were systematic and continuous rather than irregular or casual. The defendant 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 operations in Washington. A large volume of interstate business for the defendant was created through it’s agents within the state and the corporation received the benefits and protection of Washington’s laws. International Shoe had established agents in the state permanently.

Disposition

Affirmed – judgment for the plaintiff.

See Pennoyer v. Neff for a law school civil procedure case brief presenting an issue of personal jurisdiction in connection with personal service of process and quasi in rem proceedings.

The Supreme Court in Burger King Corp. v. Rudzewicz set forth the balancing factors for the personal jurisdiction reasonableness test.


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