International Shoe Co. v. Washington
326 U.S. 310 (1945)
Author: Secret Helper

Facts:

• International Shoe Co. (defendant) corporation based in Delaware
• Does business in several states
• Defendant has about 12 agents in Washington who display merchandise and accept orders. But no contracts made in Washington and no permanent business buildings of Defendant established in Washington.
• Suit brought against Defendant by Unemployment Compensation Fund of Washington in a Washington court.
• Notice personally served on one of the defendant’s agents in Washington and a copy of the notice mailed by registered mail to International Shoe Co.

Procedure:

• Superior Court and Supreme Court of Washington ruled that defendant amenable to the proceedings in the courts of Washington.

Issue:

• Can the defendant be held amenable to proceedings in Washington courts without the violation of the Due Process Clause?

Holding:

• Yes

Some Rules:

• “…the jurisdiction of courts to render judgment in personam is grounded on their de facto power over the defendant’s person.” Pennoyer v. Neff
• “…a corporation exercises the privilege of conducting activities within a state, it enjoys the benefits and protection of laws of that state.  The exercise of that privilege may give rise to obligations, and, so far as those obligations arise out of or are connected within the activities within the state, a procedure that requires the corporation to respond to a suit brought to enforce them can, in most instances, hardly be said to be undue.”

Rationale:

• Defendant conducted “systematic and continuous” business in Washington
• Large volume of interstate business for defendant created through their agents in Washington.
• Defendant and its agents received the protection of the laws of Washington
• Permanent Agents established in Washington.
• So can be held liable in Washington court
• Also, personal notice served to one of the agents was sufficient notice under Due Process Clause.
• Affirmed