International Shoe Co. v.

State of Washington* (3AM case, know it by name)

Supreme Court of the United States
326U.S. 310 (1945)

Facts

International Shoe Co. (D, appellant) was a Delaware corporation with its principle place
of business in 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 3 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 HQ in Missouri. State agency was first to decide anything in the case (that D is liable).
Administrative appeal and finally 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? (i.e. Did Int’l Shoe have corporate presence in
Wash?)

Holding and Rule

• 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.

Concurring/Dissent- Concurring, by Justice Black, who strongly stated that the 14th
Amendment and Due Process is being wrongfully used to restrict States’ powers,
including to tax.