International Shoe v. Washington (Civil Procedure 2)

Welcome to Civ Pro 2, and the discussion of “minimum contacts” in determining a court’s personal jurisdiction over a party, most specifically a defendant.

It’s somewhat non-standard, from what I gather, to start with this case and not the landmark case Pennoyer v. Neff. In this case we discuss a company, International shoe, who decides to deploy roughly a dozen or so sales people into the state of Washington to solicit business for their company. The company is incorporated in the State of Delaware, and makes their home base in Missouri. The State of Washington sues International Shoe for proceeds to be paid into the state’s unemployment fund, which they feel they are due for the past 3 years in which International Shoe has their sales members on the staff.

In this case the court draws new lines for determining personal jurisdiction over a defendant, throwing aside the prior precedent of Pennoyer v. Neff ( I will return later to analyze PvN for clarity). The court declares that since the business that International Shoe is doing within the state is continuous in nature and satisfies the new idea of them, the defendant, having minimum contacts with the state, and therefore the lawsuit can proceed.

 

Note: Most of the cases discussed in Civil procedure will have very little to do with the merits of the case itself. The issue in International Shoe v. Washington was whether or not the State could sue the company in the state of Washington, versus suing in Missouri or Delaware, in which there would be no such appeal on personal jurisdiction.

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