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International Shoe v. Washington | 326 U.S. 310 (1945)
In 1877’s Pennoyer versus Neff, the Supreme Court ruled that due process limited state courts to asserting personal jurisdiction only over state residents, persons found within the state, or those who owned property within the state. But advances in transportation and communications technology meant that by the middle of the twentieth century, businesses routinely operated beyond the confines of their home state. So, in 1945’s International Shoe Company versus Washington, the Court revisited state court jurisdiction over out-of-state parties.
The International Shoe Company, a Delaware corporation with its principal place of business in Missouri, sold goods in Washington state but didn’t pay into the state’s unemployment insurance fund. The company had roughly a dozen salespeople in Washington but didn’t maintain offices or warehouses there. Salespeople put up temporary displays, then met with customers in hotels and public spaces. Orders were sent to Missouri and filled from facilities outside Washington. The company didn’t have a registered agent in the state.
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