Fact pattern and procedural history
The state of Washington attempted to force a Delaware corporation with primary offices in Missouri to pay into a statutorily-formed state-level unemployment compensation fund. The corporation had no offices or warehouses in the state of Washington but employed a number of salespeople who were permanent residents of Washington State. The corporation resisted on the basis of a lack of jurisdiction. A chain of courts affirmed on the way up to SCOTUS.
Questions of law
What level of business conducted enables a state to claim jurisdiction over a corporation outside its borders?
The court agreed with the appellant that “the casual presence of the corporate agent or even his conduct of single or isolated items of activities in a state in the corporation’s behalf are not enough to subject it to suit.” However, it argued, “to the extent that a corporation exercises the privilege of conducting activities within a state, it enjoys the benefits and protection of the laws of that state.” It held that the activities carried out by the agent employees of the corporation were “systematic and continuous” over a lengthy period of time. Therefore the findings of the lower court were affirmed.