## Facts

- Washington assessed International Shoe Co., a Delaware corporation headquartered in Missouri, for unpaid unemployment compensation contributions for 1937–1940.
- International Shoe had no Washington office, warehouse, property, or formal place of business; it shipped shoes into Washington from facilities in other states.
- The company employed about 11–13 salesmen who lived in Washington, worked under supervision from Missouri, and were paid solely by commissions.
- The salesmen carried sample shoes, solicited orders from Washington customers, and used hotels and temporary display rooms; some rental expenses were reimbursed by the company.
- Orders were sent outside Washington for acceptance; shipments were made from outside the state.
- The company’s Washington sales activity was regular and significant, producing annual commissions exceeding $31,000 during the relevant years.
- Notice of the assessment was served on a Washington sales solicitor and also sent by registered mail to the company’s Missouri office.
- International Shoe specially appeared to contest jurisdiction and the assessment on due process and commerce clause grounds; Washington courts upheld the assessment.

## Issues

1. Whether Washington could, consistent with the Fourteenth Amendment Due Process Clause, exercise personal jurisdiction over International Shoe based on its in-state sales activities and the manner of service.
2. Whether Washington’s unemployment compensation contributions, as applied to International Shoe’s Washington-based sales force, violated due process or imposed an unconstitutional burden on interstate commerce.

## Decision

- The U.S. Supreme Court affirmed.
- Washington had personal jurisdiction because International Shoe had sufficient contacts with the state and requiring it to defend there was fair and just.
- The assessment notice procedures provided constitutionally adequate notice and opportunity to be heard.
- Washington could constitutionally exact unemployment compensation contributions tied to wages paid for services performed in Washington.

## Legal Principles

- A state may enter a judgment in personam against a nonresident defendant when the defendant has “minimum contacts” with the forum such that the suit does not offend “traditional notions of fair play and substantial justice.”
- The jurisdiction inquiry turns on the quality and nature of the defendant’s forum-related conduct and the relationship among the defendant, the forum, and the litigation, rather than on a rigid territorial “presence” rule.
- “Systematic and continuous” in-state activities that give rise to the liability sued upon support jurisdiction; more limited or isolated contacts may be insufficient, especially for claims unrelated to those contacts.
- Due process requires notice reasonably calculated to inform the defendant of the proceeding and allow an opportunity to present objections; combined in-state service on a representative and mailing to headquarters can satisfy this standard in context.
- A state may impose unemployment compensation contributions on an out-of-state employer when the obligation is fairly related to in-state employment and does not impose a constitutionally prohibited burden on interstate commerce.

## Conclusion

The Court held that a corporation conducting systematic and continuous business activities in a state through resident sales personnel has sufficient minimum contacts to justify personal jurisdiction for claims arising from those activities, and it upheld Washington’s collection of unemployment compensation contributions connected to the company’s in-state employment.


International Shoe Co. v. Washington, 326 U.S. 310 (1945)