International Shoe Co. v. Washington
Key Principles
Minimum Contacts Test: Due process requires that a defendant have minimum contacts with the forum state such that maintaining the suit does not offend traditional notions of fair play and substantial justice.
General v. Specific Personal Jurisdiction
General Personal Jurisdiction: can exist even if the claim does not arise out of or sufficiently relate to the defendant’s in-state contacts, as long as the defendant has sufficiently extensive contacts with the state (typically where they’re domiciled).
Specific Personal Jurisdiction: exists if the claim arises out of or sufficiently relates to the defendant’s deliberate contact with the state.
Case Overview
CITATION
ARGUED ON
DECIDED ON
DECIDED BY
326 U.S. 310
Nov. 14, 1945
Dec. 3, 1945
Legal Issue
Was Oklahoma’s exercise of personal jurisdiction over nonresident defendants, whose only connection to the state was a single car involved in an accident, in violation the Due Process Clause of the Fourteenth Amendment?
Holding
Yes, defendants must purposefully avail themselves
International Shoe’s factory in St. Louis, Missouri | Credit: AALS
Background
In 1976, Harry and Kay Robinson purchased a new Audi from Seaway Volkswagen, Inc. (Seaway) in New York State. The following year, the Robinsons moved to Arizona. While driving through Oklahoma on their way to their new home, the Robinsons got in a car accident when another car struck their Audi from behind, causing a fire that resulted in severe burns to Kay Robinson and her two children.
The Robinsons subsequently filed a lawsuit in the District Court for Creek County, Oklahoma, alleging that their injuries resulted from the defective design of the Audi’s gas tank and fuel system. The Robinsons joined as defendants Audi NSU Auto Union Aktiengesellschaft (the manufacturer), Volkswagen of America, Inc. (the importer), World-Wide Volkswagen Corp. (the regional distributor), and Seaway (the retail dealer). Seaway and World-Wide Volkswagen entered special appearances to argue that Oklahoma’s exercise of jurisdiction over them would offend the limitations on their jurisdiction imposed by the Due Process Clause of the Fourteenth Amendment.
World-Wide Volkswagen and Seaway are both incorporated in New York and have their principal place of business in New York. They conduct business in New York, New Jersey, and Connecticut, and there is no evidence that either do any business in Oklahoma. The District Court rejected World-Wide Volkswagen’s due process claim, so they sought a writ of prohibition in the Supreme Court of Oklahoma to restrain the District Judge, Charles S. Woodson, from exercising personal jurisdiction over them. They renewed their contention that, because they had no “minimal contacts” with the State of Oklahoma, the actions of the District Judge violated their rights under the Due Process Clause. The Supreme Court of Oklahoma denied the writ, holding that personal jurisdiction was permissible under the state’s “long-arm” statute. SCOTUS then granted certiorari.
Summary
Unanimous decision for World-Wide Volkswagen
International Shoe
Washington
Frankfurter
Murphy
Reed
Rutledge
Black
Stone
Burton
Douglas
Opinion of the Court
Writing for the Court, Chief Justice Harlan Stone held that due process requires that a defendant have minimum contacts with the forum state such that maintaining the suit does not offend traditional notions of fair play and substantial justice.
In this case, Chief Justice Stone found that International Shoe’s activities in Washington were systematic, continuous, and resulted in a substantial volume of business, therefore establishing sufficient contacts with the state. The salesmen’s activities, including displaying samples and soliciting orders, were directly tied to the obligations under the unemployment compensation statute and were sufficient to establish them as agents of International Shoe. Regarding the service of process on the salesmen and notice by registered mail to International Shoe’s home office, Chief Justice Stone stated that these satisfied the due process requirements under the Fourteenth Amendment.