Following the Great Depression, federal and state governments enacted various economic-recovery measures to get the nation back on its feet. The State of Washington passed a comprehensive unemployment scheme and required contributions from employers doing business in the state.
International Shoe Co. was an out-of-state business that sold its products in Washington, but it did not pay into the fund. The unemployment commissioner ordered International Shoe to pay up. International Shoe refused and contested the state’s exercise of personal jurisdiction over it.
International Shoe repeatedly lost in state court and ultimately appealed to the United States Supreme Court.
Writing for the majority, Chief Justice Stone held that a defendant must have minimum contacts with a state before a state could constitutionally exercise personal jurisdiction over that defendant. Minimum contacts might exist if a defendant had continuous, systematic contact with the state.
Conversely, the required contacts could be satisfied by only a few, sufficiently meaningful contacts. Because International Shoe had systematic contact with the state, Washington’s exercise of personal jurisdiction did not offend traditional notions of fair play and substantial justice and was thus valid.
Today, International Shoe v. Washington, remains part of the bedrock of American civil procedure.
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