Overview
This lecture covers the Supreme Court case International Shoe Co. v. Washington and the development of specific in personam jurisdiction in U.S. civil procedure.
International Shoe Co. v. Washington
- International Shoe was a Delaware corporation with headquarters in Missouri, selling shoes in Washington through salesmen.
- Washington sued International Shoe for unpaid unemployment taxes.
- International Shoe argued that state courts lacked personal jurisdiction because it had no physical presence in Washington.
- The Supreme Court held that "minimum contacts" with the forum state can establish personal jurisdiction.
- The company had sufficient contacts through its salesmen to be subject to Washington's jurisdiction.
Specific In Personam Jurisdiction
- In personam jurisdiction refers to a court's power over an individual or entity.
- Specific jurisdiction applies when the lawsuit arises out of or relates to the defendant’s activities in the forum state.
- The court must find minimum contacts that make jurisdiction reasonable and fair ("traditional notions of fair play and substantial justice").
- The contacts must be purposeful, meaning the defendant targeted or benefited from the forum state.
Effects of the International Shoe Ruling
- Shifted analysis from physical presence to minimum contacts for personal jurisdiction.
- Enabled states to assert jurisdiction over out-of-state businesses with significant in-state business activities.
- Laid the foundation for modern personal jurisdiction doctrine, especially in cases involving interstate commerce.
Key Terms & Definitions
- Personal Jurisdiction — a court's authority over the parties involved in the lawsuit.
- In Personam Jurisdiction — jurisdiction over the person or entity, as opposed to property.
- Specific Jurisdiction — jurisdiction based on claims arising from the defendant’s activities in the forum state.
- Minimum Contacts — sufficient connections between the defendant and the forum state to justify jurisdiction.
- Fair Play and Substantial Justice — due process standard ensuring jurisdiction is reasonable and just.
Action Items / Next Steps
- Review the facts and holding of International Shoe Co. v. Washington.
- Read assigned textbook sections on personal jurisdiction and minimum contacts.
- Prepare examples of minimum contacts for class discussion.