ProfessorBrittany L. Raposa
CaseCast™ – "What you need to know"
Brief Fact Summary. Defendant was an out of state company that employed salesmen within the state of Washington. Washington sued Defendant to recover unpaid unemployment taxes and served Defendant in two ways: (1) by mail and (2) by serving one of its salesmen within the state. Defendant appealed from a verdict for Washington, claiming that Washington had no personal jurisdiction over Defendant.
Synopsis of Rule of Law. In order for a state to exercise personal jurisdiction over a defendant, the defendant must have such minimum contacts with the state so that exercising jurisdiction over the defendant would not offend “traditional notions of fair play and substantial justice.”
Issue. Is service of process upon Defendant’s agent sufficient notice when the corporation’s activities result in a large volume of interstate business so that the corporation receives the protection of the laws of the state and the suit is related to the activities which make the corporation present?
Held. Yes. Affirmed. The general rule is that in order to have jurisdiction with someone outside the state, the person must have certain minimum contacts with it such that the maintenance of the suit does not offend “traditional notions of fair play and substantial justice. For a corporation, the “minimum contacts” required are not just continuous and systematic activities but also those that give rise to the liabilities sued on. Defendant could have sued someone in Washington. It was afforded the protection of the laws of that state, and therefore it should be subject to suit.
Dissent. The state’s power to tax should not be qualified by an ambiguous statement regarding fair play and substantial justice.
Discussion. This decision articulates the rule for determining whether a state has personal jurisdiction over an absent defendant via the “minimum contacts” test. In general, International Shoe demonstrates that contacts with a state should be evaluated in terms of how “fair” it would be to exercise jurisdiction over an absent defendant.