International Shoe Co. v. Washington

International Shoe Co. v. Washington
Supreme Court of the United States, 1945.
326 U.S. 310, 66 S.Ct. 154, 90 L.Ed. 95.

Facts: Washington had a statute that required employers to pay a certain amount per year into a state unemployment fund. (The amount is a percentage of the wages paid annually by an employer for his employees' "services in the state.") International Shoe Co., a Delaware corporation, never made those contributions. Washington personally served a sales solicitor employed by I.S. Co. in the state, and mailed a copy to the St. Louis, Missouri address of I.S. Co. I.S. Co. refused to pay, and claimed that service upon the salesman wasn't proper service to I.S. Co., and that the company was not based in Washington nor doing business there, nor employing anyone there within the meaning of the statute.

Procedure: I.S. Co. appeared before the office of unemployment to appeal, and the unemployment tribunal ruled against I.S. Co.; the Commissioner affirmed (the Commissioner was also a party to that tribunal?). Both the Superior Court and the Supreme Court of Washington affirmed. Appellant, I.S. Co., says the statutes as applied infringe the 14th Amendment's due process clause and the commerce clause.

Issue: Did the appellant submit themselves to Washington's jurisdiction via the 14th Amendment? And, is the statute (as applied) even legal via the 14th Amendment?

Holding: Yes and yes.

Reasoning: It's difficult to see where the line is drawn for substantial behavior within a state, but the amount of time and consistency of behavior involved seems to put I.S. Co on the substantial behavior side of it- so yes, there was jurisdiction. And no, the statute is not being pursued in such a way to violate either due the process or commerce clause.