International Shoe Co. v Washington

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?

Finding

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.

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