Also known as: General Shoe · minimum contacts
Written by attorneys · grounded in primary & secondary sources — see below
A constitutional standard for personal jurisdiction that requires a defendant to have minimum contacts with the forum state such that maintaining the suit does not offend traditional notions of fair play and substantial justice.
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Granite Holdings, based in State A, negotiated a supply contract solely through emails and calls with Glacier Energy in State B. Glacier Energy never entered State A and structured performance to occur entirely in State B. When Granite Holdings sued in State A for breach, Glacier Energy moved to dismiss for lack of personal jurisdiction. The court granted the motion because Glacier Energy's remote dealings did not constitute purposeful availment of State A.
International Shoe maintained a team of salesmen who resided in and continuously solicited orders throughout State A over several years. When the state sued to collect unemployment contributions, the company contested personal jurisdiction. The court upheld jurisdiction because the systematic and continuous contacts satisfied the minimum contacts standard and did not offend fair play.
Gable Construction owned a single parcel of land in State A that was unrelated to any dispute. A plaintiff sued Gable Construction in State A over a contract performed entirely in State B and sought to base jurisdiction on the presence of the land. The court dismissed the action because the property alone could not support jurisdiction over an unrelated claim.
A defendant must have minimum contacts with the forum state such that the suit does not offend traditional notions of fair play and substantial justice.
Supporting sources
No. The defendant itself must purposefully avail itself of the forum. Unilateral activity of another party cannot create jurisdiction.
Supporting sources
No. The minimum contacts standard applies to all exercises of state-court jurisdiction, and unrelated property alone is insufficient.
Supporting sources
…Basis of Card Majority, 3 Ga. L. Rev. 334, 347 (1969). [^8]: See, e. g., Aaron Brothers , 158 N. L. R. B. 1077 (1966); cf., General Shoe Corp. , 77 N. L. R. B. 124 (1948). An employer, of course, may not, even if he acts in good faith, recognize a minority union, Garment Workers' Union v. NLRB , 366 U. S. 731 (1961). [^9]:…