Also known as:International Shoe · minimum contacts analysis · International Shoe test · Intl. Shoe · minimum contacts · personal jurisdiction analysis
Written by attorneys · grounded in primary & secondary sources — see below
A constitutional standard for determining whether a court may exercise personal jurisdiction over a nonresident defendant. The analysis requires minimum contacts with the forum state such that the suit does not offend traditional notions of fair play and substantial justice.
Sources & Authorities
How it applies
Common Examples
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Remote Contract Negotiations
Island Manufacturing in State B negotiated a supply contract with Insight Consulting in State A solely through emails and calls directed to State A. Insight sued Island in State A for breach after a shipment dispute. The court found no purposeful availment because Island never entered or targeted State A beyond responding to the plaintiff.
Ongoing Commercial Dealings
Iris Energy in State C sold equipment repeatedly to Imperial Motors in State D over two years. Imperial sued Iris in State D after a defective unit caused losses. The court upheld jurisdiction because the repeated sales created minimum contacts that made the suit fair under due process.
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Cases
Restatements
Study Supplements
Isla Ireland owned vacant land in State E but lived and worked exclusively in State F. A plaintiff sued her in State E over an unrelated contract claim and attached the land. The court dismissed because the property alone did not create sufficient contacts for jurisdiction over the unrelated dispute.
Stream of Commerce Component
Israel Irving manufactured valves in State G and sold them to a distributor that resold them nationwide. A State H buyer sued after a valve failed. The court examined whether mere awareness of possible resale satisfied minimum contacts without additional forum targeting.
Asahi Metal Industry Co. v. Superior Court of Cal., Solano Cty.480 U.S. 102 (1987)
Market Share Acquisition
Isaiah Ishikawa acquired a competitor with substantial operations in State I. A State I plaintiff sued over the acquisition. The court assessed whether the acquisition created contacts sufficient for jurisdiction over the claim.
Brown Shoe Co. v. United States370 U.S. 294, 305, 82 S.Ct. 1502, 1513, 8 L.Ed.2d 510 (1962)
Subsidiary Sales Network
Ira Irving's foreign tire subsidiary sold products through a U.S. distributor that placed substantial volume in State J. Injured State J residents sued the parent. The court evaluated whether the subsidiary's forum sales supported general jurisdiction over the parent.
Goodyear Dunlop Tires Operations, S.A. v. Brown564 U.S. 915, 919 (2011)
Common questions
Frequently Asked
4
What must a defendant do to satisfy purposeful availment under the analysis?+
The defendant must deliberately reach into the forum to create a substantial connection, such as by directing sales, negotiations, or services at forum residents. Unilateral actions by the plaintiff or third parties do not count.
Does the analysis apply to quasi in rem jurisdiction?+
Yes. The minimum contacts test governs all exercises of state court jurisdiction, so the mere presence of property unrelated to the claim is insufficient.
How does the analysis differ from older territorial power rules?+
It replaces rigid presence requirements with a flexible inquiry into contacts, relatedness, and fairness so that jurisdiction comports with due process even when the defendant has no physical presence.
Can remote communications alone create jurisdiction under the analysis?+
They can if they show deliberate targeting of the forum and the claim arises from that relationship, but isolated or plaintiff-initiated contacts are usually insufficient.
326 U.S. 310 (1945)Civil Procedure
International Shoe Co. v. Washington <!-- acedexams opinion md v1 -- Case information - Court: Supreme Court of the United States - Citation: 326 U.S. 310, 66 S.Ct. 154, 90 L.Ed. 95, 161…