International Shoe Co. v. Washington

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

Facts

A Delaware corporation, with its principal place of business in Missouri, employed 11-13 salesmen residing in Washington to continuously solicit orders for shoes. These salesmen displayed samples and transmitted orders to Missouri for acceptance, with goods shipped from outside Washington. The State of Washington sought to collect unpaid unemployment compensation contributions from the corporation, serving notice on a salesman and mailing it to the Missouri office.

Issue

Can a state subject a foreign corporation to suit in its courts and collect unemployment compensation taxes, consistent with the Due Process Clause of the Fourteenth Amendment, when the corporation's only activities in the state are the continuous and systematic solicitation of orders by resident salesmen?

Holding

Yes. The Supreme Court affirmed the Washington Supreme Court's decision, holding that the corporation's continuous and systematic activities in Washington were sufficient to establish minimum contacts for personal jurisdiction and taxation under the Due Process Clause.

Rule

For a state to exercise personal jurisdiction over a foreign corporation, due process requires that the corporation have "certain minimum contacts" with the state such that the maintenance of the suit "does not offend 'traditional notions of fair play and substantial justice.'" These contacts must be systematic and continuous, and the obligation sued upon must arise out of or be connected with those activities.

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Case brief last reviewed 2026-05-01. Prepared by CaseReader from the published opinion.