INTERNATIONAL SHOE V STATE OF WASHINGTON In rem jurisdiction: A court’s power to adjudicate the rights to a given piece of property

JUN 24 1997 | MARSHALL, J  Including power to seize and hold it

Facts
Appellant principle location in St. Louis, Missouri, incorporated in Delaware. They had
13 salesmen in Washington, working for them. However, the salesmen had limited responsibilities
and powers. They were no allowed to enter into a contract on behalf of the corporation. The
salesmen showed the shoes for sale, and if someone wanted to make a purchase, they would
carry out the transaction directly with the headquarters in Missouri, and the appellants would ship
the merchandise F.O.B. (once it leaves vendor's warehouse,
it becomesproperty of the buyer). Salesmen were paid commissions. Washington State
attempted to collect unemployment compensation from the Missouri-based corporation, and they
served one of the salesmen in Washington and mailed a notice via registered mail to the
corporation last known address in St. Louis. Appellant moved to set aside the notice and order on
the grounds that they are not a corporation of Washington, do not do their business in Washington,
and nor do they have employees in Washington which could be served.

 State of Washington sued International Shoe to recover unpaid contribution’s to state

unemployment fund
o International Shoe did not have an office in Washington, but employed 11-13
salesmen there who conducted business on International Shoe’s behalf
 When Washington sued the company, they served notice personally to one of the salesman
and mailed a notice to the company’s St. Louis headquarters
 Washington Supreme Court upheld the state’s right to sue

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

To have specific jurisdiction in a state, a defendant must "have certain minimum contacts with it
such that the maintenance of the suit does not offend 'traditional notions of fair play and
substantial justice.'" The salesman working with the corporation inside Washington State were
sufficient as minimum contacts. The maintenance of the suit did not offend "traditional notions
of fair play and substantial justice,' since the corporation' s business dealings in Washington were
very systematic, over a period of several years. They resulted "in a large volume of interstate
commerce," and in which time the appellant received the benefits and protections of the state in
which they were conducting business. They established sufficient contacts with the state that it is
fair and just to have jurisdiction

Reasoning
 Test is subjective as to the minimum contacts requirement
o Minimum contacts does not offend traditional notions of fair play and substantial
justice
 International Shoe had conducted “systematic and continuous” business in Washington.
o 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.
 If you enjoy the protection of the laws of a state, you also have the
obligations
o D had established agents in the state permanently.
 Quality and nature of the contacts is to be analyzed, not simply the quantity
o There was sufficient notice of the suit

In personam jurisdiction: A court’s power to bring a person into its adjudicative process
 Jurisdiction over a defendant’s personal rights