International Shoe v Washington

1945

Venue: SCOTUS

Facts: Shoe is a DE corp with pricipal place of business in St. Louis, MO. They've got sales people in WA, though, and one of these got served.

Posture: Special appearance to object to service and maybe even subject matter. Appeal from unfavorable ruling.

Issue: Does doing business in a state subject you to jurisdiction there, and if so can the state collect taxes consistent with the due process clause?

Holding: Yes and yes. Affirmed.

Rule: To the extent a corporation derives benefits from the protection of a state's laws, it incurs obligations arising out of its activities within that state, so it's not undue to allow the state to enforce its requirements.

Reasoning: Continuous and systematic activities make corporations present. Whether there is jurisdiction will depend on the quality and nature of the activities in relation to the laws.

These here activities were neither irregular nor casual, and they went on for years and resulted in a lot of business.


Dicta: Black, concurring: Phrases like "fair play," and "reasonableness" don't turn up in the constitution, and we shouldn't use them to decide constitutional issues, because they're too elastic.