International Shoe v. Washington: Minimum Contacts Explained

International Shoe was a Delaware corporation headquartered in Missouri. It had no offices in Washington but employed 11-13 salespeople there who displayed samples and solicited orders. Washington sued International Shoe for unpaid unemployment contributions. The question: Did Washington have personal jurisdiction over International Shoe?

Chief Justice Stone held that due process requires the defendant have “certain minimum contacts” with the forum state such that maintaining the suit does not offend “traditional notions of fair play and substantial justice.” This replaced Pennoyer's rigid physical presence requirement with a flexible, fact-specific inquiry focused on the defendant's connections to the forum.

Stone outlined a spectrum of contacts:

Continuous and systematic + related to claim: Jurisdiction clearly proper (specific jurisdiction)
Continuous and systematic + unrelated to claim: Jurisdiction may be proper (general jurisdiction)
Isolated + related to claim: Jurisdiction may be proper depending on nature of contacts
Isolated + unrelated: Jurisdiction improper

International Shoe is the foundation of modern personal jurisdiction analysis. Every personal jurisdiction question — from Civ Pro exams to Supreme Court cases — begins with International Shoe's minimum contacts framework. The case adapted constitutional jurisdictional requirements to a modern economy where businesses operate across state lines without maintaining physical presence everywhere.