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International Shoe Co. v. Washington
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| International Shoe Co. v. Washington | |
| Reference: 326 U.S. 310 | |
| Term: 1945 | |
| Important Dates | |
| Argued: November 14, 1945 Decided: December 3, 1945 | |
| Outcome | |
| Washington Supreme Court affirmed | |
| Majority | |
| Harlan Fiske Stone • Stanley Reed • Felix Frankfurter • William Douglas • Frank Murphy • Wiley Rutledge • Harold Burton | |
| Concurring | |
| Hugo Black | |
International Shoe Co. v. Washington was a case decided on December 3, 1945, by the United States Supreme Court holding that state courts have jurisdiction when a defendant has minimum contacts with the state. The case concerned a lawsuit filed by the state of Washington against a Delaware corporation for unpaid unemployment fund contributions, on the grounds that the corporation should be required to contribute because it employed Washington residents. The Supreme Court affirmed the ruling of the Washington Supreme Court.[1][2]
Why it matters: The Supreme Court's decision in this case established that states have jurisdiction over the actions of non-resident corporations when they have minimum contacts with the state. To read more about the impact of International Shoe Co. v. Washington click here.
Background
International Shoe Co. was a Delaware corporation that had its main location in St. Louis, Missouri. The corporation also employed several salesmen from the state of Washington, where they resided and worked. The state filed a lawsuit against International Shoe Co. for refusing to contribute to the state's unemployment compensation fund. The corporation argued that the state of Washington did not have jurisdiction over it because its business was not in the state. The state court ruled against the corporation, to which International Shoe Co. appealed to the Supreme Court.[2]
Oral argument
Oral argument was held on November 14, 1945. The case was decided on December 3, 1945.[1]
Decision
The Supreme Court decided 8-0 to affirm the decision of the Washington Supreme Court. Chief Justice Harlan Fiske Stone delivered the opinion of the court. Justice Hugo Black wrote a concurring opinion. Justice Robert H. Jackson did not participate in the case.[1]
Opinions
Opinion of the court
Chief Justice Harlan Fiske Stone, writing for the court, argued that the actions of International Shoe Co. in the state of Washington were "systematic and continuous." Stone contended that, as a result of such actions, the corporation was subject to benefits from state law and therefore must also be subject to the jurisdiction of the state court.[1]
| “ | Applying these standards, the activities carried on in behalf of appellant in the State of Washington were neither irregular nor casual. They were systematic and continuous throughout the years in question. They resulted in a large volume of interstate business, in the course of which appellant received the benefits and protection of the laws of the state, including the right to resort to the courts for the enforcement of its rights. The obligation which is here sued upon arose out of those very activities. It is evident that these operations establish sufficient contacts or ties with the state of the forum to make it reasonable and just, according to our traditional conception of fair play and substantial justice, to permit the state to enforce the obligations which appellant has incurred there. Hence, we cannot say that the maintenance of the present suit in the State of Washington involves an unreasonable or undue procedure.[3] | ” |
| —Harlan Fiske Stone, majority opinion in International Shoe Co. v. Washington[1] | ||
Concurring opinion
Justice Hugo Black, in a concurring opinion, agreed with the decision of the court and argued that states should have jurisdiction over corporations that conduct business within their borders.[1]
| “ | I believe that the Federal Constitution leaves to each State, without any 'ifs' or 'buts,' a power to tax and to open the doors of its courts for its citizens to sue corporations whose agents do business in those States. Believing that the Constitution gave the States that power, I think it a judicial deprivation to condition its exercise upon this Court's notion of 'fair play,' however appealing that term may be. Nor can I stretch the meaning of due process so far as to authorize this Court to deprive a State of the right to afford judicial protection to its citizens on the ground that it would be more 'convenient' for the corporation to be sued somewhere else.[3] | ” |
| —Hugo Black, concurring opinion in International Shoe Co. v. Washington[1] | ||
Impact
| Federalism |
|---|
|
| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
International Shoe Co. v. Washington established that states have jurisdiction over the actions of non-resident corporations when they have minimum contacts with the state.[1]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 Justia, "International Shoe Co. v. Washington, 326 U.S. 310 (1945)," accessed September 22, 2022
- ↑ 2.0 2.1 LexisNexis, "Int'l Shoe Co. v. Washington - 326 U.S. 310, 66 S. Ct. 154 (1945)," accessed September 22, 2022
- ↑ 3.0 3.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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